Financial
With DMTT coming into effect on Jan 1st, 2025, a tax expert explains everything businesses in Bahrain need to know
Last September, the Kingdom of Bahrain introduced a new law to implement a Domestic Minimum Top-up Tax (DMTT) at a rate of 15% on businesses operating in the Kingdom that meet certain criteria.
With the tax coming into effect in time for the new year, Mr. Nilesh Ashar, an international tax specialist with more than 25 years of experience, serving as Senior Managing Director & Head of Tax Middle East at FTI Consulting, provided a comprehensive overview of the new law and its implications for businesses in Bahrain.
Mr. Ashar stated that the Kingdom’s decision is a significant milestone in the Middle East, with Bahrain emerging as a front runner to implement the DMTT on large multinational enterprises (MNEs) having presence in the Kingdom.
“The new law underscores Bahrain’s international commitment as part of the inclusive framework of the Organization for Economic Cooperation and Development (OECD), to address base erosion and profit shifting by MNEs,” stated Mr. Ashar.
“Effective January 1st, 2025, onwards, the law is largely based on the OECD Model Rules on global minimum tax (GMT) in terms of calculation of the tax, exclusions, and reliefs. Additionally, the new law contains specific provisions on procedures, enforcement, and anti-avoidance measures applicable in the Kingdom.”
While explaining who will be affected by this tax, and what the law actually entails, he added that the new law applies a 15% tax on the income of Bahrain entities (including permanent establishment, joint venture, and JV subsidiaries) that are part of an MNE group with annual consolidated revenue exceeding €750 million, for at least two out of four preceding fiscal years. However, the tax does not apply to foreign subsidiaries of a Bahraini-headquartered group or other foreign group companies that are part of the same MNE group. The DMTT is also not applicable to certain excluded entities as specified in the law, including government bodies, international organizations, non-profit organizations, sovereign wealth funds, pension funds, and certain investment funds.
Mr. Ashar explained that the law lists specific transitional and permanent reliefs from the levy of DMTT, including transitional country-by-country safe harbor relief, exclusion for the initial phase of international activity, de-minimis exclusion, and simplified computation safe harbor relief.
Describing key considerations for businesses, Mr. Ashar said that, since the law is effective from January 1st, 2025, and detailed rules (Executive Regulations) are expected to be published in the coming months, it is now imperative for businesses to assess the impact of the DMTT on their Bahrain presence, evaluate the availability of any reliefs, and prepare for the compliances to be undertaken based on the law read in conjunction with the OECD Model Rules.
Mr. Ashar described, “In terms of taxable income, this is defined in the law as the financial accounting net income or loss for the fiscal year, before making any consolidation adjustments eliminating intra-group transactions, in accordance with the local accounting standards. Detailed rules on calculation of taxable income will be prescribed in line with the OECD Model Rules. Several compliance obligations are specified in the law including obtaining a registration, filing of annual tax returns, and paying taxes in advance over the relevant fiscal year. These compliances are expected to be in addition to the notifications and filings as required by the MNE Group under the OECD Model Rules.”
In addition, the law also provides specific provisions on enforcement via conduct of tax audits, assessments and procedures in relation to litigation and appeals. Mr. Ashar noted that a Tax Objection Committee will be formed for this purpose. Also, penal consequences are laid out in case of defaults, like failure to obtain registration, file tax returns, or submitting incorrect data. Such defaults may trigger stringent administrative fines, without prejudice to criminal liability.
Mr. Ashar further explained that a general anti-avoidance rule empowers the National Bureau of Revenue to disregard any transaction if it is not genuine or its primary purpose is to obtain a tax advantage against the objective of the law. Furthermore, the law specifies certain acts to qualify as ‘tax evasion,’ resulting in onerous consequences including criminal liability for legal persons, if held responsible for such evasion. Dispute resolution through a settlement process is acknowledged.
Mr. Ashar concluded that the Executive Regulations to the law are yet to be issued and are expected to prescribe detailed rules, controls and manner of calculation and application of DMTT in a manner consistent with the Model Rules. He also noted that since the law is published in the Arabic language, his views are based on an unofficial translation of the law.
Financial
Al Ansari Exchange Partners with RTA Dubai to Offer nol Travel Cards
Al Ansari Exchange, the UAE’s leading remittance and foreign exchange company and a subsidiary of Al Ansari Financial Services PJSC (DFM: ALANSARI), has partnered with Dubai’s Roads and Transport Authority (RTA) and in association with MDX Technology Solutions ME, to make nol Travel Cards available at selected branches across Dubai.
The collaboration broadens Al Ansari Exchange’s portfolio of third-party products and extends access to Dubai’s integrated mobility payment system through the UAE’s largest branch networks. It also reflects the company’s strategy of building a connected physical and digital ecosystem that provides customers with convenient access to a wider range of everyday financial and lifestyle services.
Residents and visitors can now purchase nol Travel Cards from selected Al Ansari Exchange branches, distributed through MDX Technology Solutions ME, the RTA-authorised distributor of nol Travel Cards, providing an additional point of access to one of Dubai’s most widely used mobility payment solutions.
The nol Travel Card enables cashless payments across Dubai’s public transport network, including the Dubai Metro, Dubai Tram, public buses, marine transport and public parking. It is also accepted at more than 14,000 retail outlets across the UAE. Through the nol Pay App, cardholders can access more than 200 lifestyle offers and discounts.
Commenting on the collaboration, Musad Ibrahim Alhammadi, Director of Automated Collection Systems at Corporate Technology Support Services Sector, Roads and Transport Authority (RTA), said: “Expanding the availability of nol Travel Cards through strategic collaborations supports RTA’s efforts to make mobility services more accessible across Dubai. Providing additional distribution channels contributes to wider adoption of digital payment solutions and enhances the travel experience for residents and visitors.”
Ali Al Najjar, Chief Executive Officer of Al Ansari Exchange, added: “As customer expectations continue to evolve, we are expanding the role of Al Ansari Exchange beyond traditional financial transactions by bringing together financial, payment and everyday lifestyle services through both our branch network and digital platforms. Making nol Travel Cards available through our branches complements our broader strategy of creating a seamless customer experience while supporting Dubai’s vision for a smart, digitally connected city.”
Financial
The rights you think you have: five legal stress tests for a more resilient business
Resilience is not only about cash reserves, backup servers or alternative suppliers. It also depends on whether a company’s legal rights and permissions still work when the business is under pressure.
By: Maroun Abou Harb, Associate at BSA LAW
Resilience is discussed as an operational or financial discipline. Businesses test liquidity, back up systems and diversify supply chains. Yet every continuity plan rests on legal infrastructure: licenses, delegated authorities, contracts, data permissions, employment arrangements, security rights and evidence.
That infrastructure can fail when needed most. The replacement supplier cannot be appointed without third-party consent. Customer data cannot lawfully be moved to the backup provider. An insurance claim is compromized by late notification. A guarantee was signed incorrectly. The company owns a platform, but not all of its intellectual property.
The most dangerous legal risk is not the missing clause. It is the right management assumes the business has, but cannot use.
In the UAE, the Central Bank’s 2026 Operational Risk Management Regulation now requires licensed financial institutions to implement a comprehensive operational risk and resilience proecedure. The principle is valuable for every company: identify what must continue, locate the legal points of failure and test them before disruption does.
- Can the business lawfully act?
Start with corporate authority, check that licenses match actual activities, constitutional documents reflect the ownership and governance structure, and beneficial-owner, shareholder and director records are accurate. Review reserved matters, signing matrices, powers of attorney and banking mandates.
A deal, borrowing or emergency payment can stall because the authorized signatory is unavailable, a power has expired or an approval threshold was misunderstood. Group companies should confirm which entity employs people, owns assets, contracts with customers and receives revenue.
Run this scenario: if the chief executive and chief financial officer were unreachable tomorrow, who could bind the company, access its accounts and appoint an alternative supplier? If the answer is uncertain, the business has a legal single point of failure.
- Which contracts become dangerous under stress?
Most contract reviews examine value and liability. A resilience review asks a different question: what happens when performance is interrupted?
Build a heat map of critical customer and supplier contracts, ranked by operational importance and consequence of failure. For each, test termination and suspension rights, force majeure and change-in-law provisions, service levels, price-adjustment mechanisms, liability caps, indemnities, insurance, governing law and dispute forum, subcontracting, assignment and change-of-control restrictions. Check notice methods and cure periods; a valuable right can disappear if a notice is sent late or to the wrong address.
Then examine optionality, can the company use a replacement supplier, obtain transition assistance, retrieve its data in a usable format and continue using essential intellectual property? Is there a source-code escrow or step-in mechanism where appropriate?
The aim is not to renegotiate every contract. It is to know which five contracts could stop the business and to fix those first.
- Can technology fail without the legal part failing too?
A technical recovery plan is incomplete if the contracts do not support it. Cloud, payment, telecommunications and managed-service arrangements should align promised recovery times with the company’s tolerance for disruption. Audit rights, incident cooperation, subcontractor controls, data-location commitments and exit assistance should be tested.
The incident playbook must allocate legal decisions. Who determines whether regulators, customers, insurers or affected individuals must be notified? Who preserves evidence and engages external advisers? How will legal privilege or professional confidentiality be preserved? A cyber incident moves quickly; ambiguity over decision-making wastes the hours that matter most.
Conduct an exercise with management, technology, legal, communications and finance. Introduce a realistic vendor outage or data breach and follow the contracts: who calls whom, what must be notified, and what can actually be recovered?
- Does the company know what data and technology it is using?
Across the GCC, privacy and cybersecurity regimes increasingly regulate how data is collected, processed, retained, transferred and protected. A company cannot comply, or recover confidently, without knowing where its data goes.
Create a data map covering customers, employees, vendors and website users. Record the purpose and legal basis for processing, storage location, access rights, retention period, cross-border transfers and third-party processors.
The same exercise should include artificial intelligence, by identifying public and embedded AI tools, the information supplied to them, the outputs relied upon and the human review applied. Confidential information, personal data and third-party intellectual property should not enter a tool because an employee can access it. An approved-use policy, procurement review and output-verification process are proportionate safeguards.
- Can the company protect value when conditions deteriorate?
Management should monitor covenant breaches, unpaid taxes, overdue receivables, expiring insurance, threatened claims and counterparties showing signs of insolvency. The legal team should know which rights permit suspension, security enforcement, contract termination or protective court relief, and whether exercising them could create risk.
People and intellectual property also require continuity planning. Confirm that employment and consultancy terms contain appropriate confidentiality, invention-assignment and post-termination protections, tailored to the governing law. Identify key-person dependencies, succession gaps and access held by departing staff. Register intellectual property where appropriate and maintain evidence of creation and ownership.
Business needs also to review insurance as a contract, not a certificate. Map material risks to coverage, exclusions, deductibles, notification deadlines and consent requirements. The policy is only useful if the company knows how to activate it.
In brief, the output should be that for every critical risk, record the business service affected, relevant entity and contract, responsible owner, required action, deadline and escalation threshold.
Report the highest exposures to the board and repeat the exercise after major acquisitions, restructurings, regulatory changes or technology deployments.
A focused review can produce four useful assets:
- an authority and obligations calendar;
- a critical-contract heat map;
- a data and AI inventory; and
- a tested incident playbook.
No company can remove disruption. It can, however, remove the uncertainty surrounding who may act, what must be done and which rights remain available.
Financial
Tax Is Not a Strategy – Why Dubai’s Smartest Founders Think Beyond Zero Per Cent
By Joe David, CEO of Nephos Group
“Move to Dubai for tax.”
I hear this constantly. From founders, investors, crypto-native operators – people building real businesses who reduce one of the biggest decisions of their professional lives to a single line on a spreadsheet.

And honestly, it is the wrong way to think about it.
Tax should rarely be the sole reason to relocate. When it is, it is usually where things go wrong. The corporate structure is not set up correctly. The banking relationships are not in place. The founder leaves within 18 months because the deeper rationale was never really there. I have seen this pattern play out dozens of times over the past decade, and it almost always traces back to the same root cause: a decision built on a tax rate rather than a strategy.
The tax-first trap
Dubai’s zero per cent personal income tax rate is real, and it is significant. But leading with tax creates a narrow frame that obscures the fuller picture. Founders who relocate purely for a rate often fail to consider the operational realities of building in a new jurisdiction. They underestimate the compliance infrastructure required to make the move defensible. They overlook the substance requirements that tax authorities in their home countries will scrutinise. When the expected savings do not materialise cleanly, because the structure was an afterthought, disillusionment sets in fast.
This does Dubai a disservice. It reduces a genuinely world-class business environment to a line in a tax planning brochure. The city deserves better than that, and so do the founders making life-altering decisions based on incomplete thinking.
What the successful ones actually optimise for
The founders and investors who get the most out of Dubai are not chasing a tax rate. They are making a broader strategic move.
Jurisdictional access is a major factor. Dubai sits at the crossroads of Europe, Africa and Asia, offering time zone coverage and travel connectivity that few cities can match. For businesses operating across multiple markets, particularly in digital assets, fintech and professional services, that geographic positioning is a genuine competitive edge.
Then there is the capital environment. Dubai has become a magnet for institutional and private capital, with fund structures, family offices and venture vehicles establishing a permanent presence. The banking infrastructure, while still maturing in certain areas, has improved significantly. For crypto-native businesses in particular, the regulatory clarity offered by frameworks like the Virtual Assets Regulatory Authority (VARA) provides something that many Western jurisdictions still cannot: a clear, codified path to operating legally with digital assets.
The business ecosystem itself is another draw. The speed at which you can incorporate, hire, open accounts and begin operating is remarkable compared to legacy jurisdictions. Free zones offer tailored licensing, and the government’s responsiveness to emerging sectors – AI, blockchain, tokenised finance – signals a jurisdiction that is building forward rather than regulating backward.
And then, yes, there is the lifestyle. Climate, safety, connectivity, quality of infrastructure. These are not trivial considerations when you are asking a founding team to commit to a base for the next five to ten years.
Tax is often the outcome of all of this. It is not the strategy itself.
The compliance landscape is shifting
There is another reason the tax-first mindset is increasingly risky. The global compliance environment is tightening rapidly. The Crypto-Asset Reporting Framework (CARF), developed by the OECD, will require automatic exchange of information on crypto transactions between jurisdictions. The EU’s DAC8 directive introduces similar obligations across member states. The days of relocating and assuming your home country’s tax authority will not follow are numbered.
This means that substance, genuine economic activity, real operational presence, defensible corporate structures, matters more than ever. A Dubai relocation that is purely cosmetic will not survive scrutiny. One that is built on genuine strategic foundations, with proper advisory support and compliant structures, will.
The conversation worth having
None of this is an argument against moving to Dubai. Quite the opposite. For the right founder, with the right business, at the right stage, it can be a transformative decision. But that decision needs to be grounded in strategy, not arithmetic.
Before you start calculating your tax savings, ask the harder questions. Does your business model benefit from being in this jurisdiction? Can you build genuine substance here? Are your corporate structures defensible under international reporting frameworks? Do you have the advisory infrastructure to get this right from day one?
That distinction – between tax as a tactic and strategy as a foundation – matters more than most people realise. And it is a conversation worth having before you make any decisions.
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