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With DMTT coming into effect on Jan 1st, 2025, a tax expert explains everything businesses in Bahrain need to know

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DMTT

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.

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Financial

ATHAR+ LAUNCHES 2ND HACK4IMPACT HACKATHON IN ABU DHABI

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Athar+, Abu Dhabi’s first purpose-driven hub dedicated to accelerating social impact, operated by the Authority of Social Contribution – Ma’an, has launched the second edition of its HACK4IMPACT hackathon, bringing together changemakers to develop practical solutions that address key social priorities and contribute to positive social impact across Abu Dhabi.

Launched in line with the objectives of the UAE’s Year of Family, this edition of the hackathon focuses on addressing family-related challenges through innovative and community-driven approaches. Taking place from 16-18 June 2026 at Athar+, the three-day programme brings together aspiring entrepreneurs, innovators, professionals, and community members to develop solutions addressing three family-centred priorities: building stronger family foundations, enhancing financial wellbeing for parents, and supporting families caring for aging parents.

Guided through a structured innovation journey, participants will apply design thinking methodologies to explore challenges, validate ideas, develop prototype concepts, and present their solutions to a panel of judges.

High-potential concepts emerging from the hackathon have the opportunity to be considered for further support through Athar+’s incubation ecosystem, enabling participants to continue developing their solutions beyond the event. Through these challenge areas, the initiative aims to advance family wellbeing, strengthen social cohesion, and support the development of solutions that respond to the evolving needs of families in Abu Dhabi.

This initiative aims to strengthen practical innovation skills among participants while identifying high-potential ideas and scalable concepts capable of addressing key social priorities. It also encourages collaboration by bringing together individuals from diverse backgrounds and expertise. The hackathon provides an accessible entry point for youth and first-time innovators to contribute to solving community challenges through entrepreneurship and social innovation, inspiring them to play an active role in shaping impactful and practical solutions.

His Excellency Salem AlShamsi, Executive Director of Social Incubation and Contracting at Ma’an said: “HACK4IMPACT reflects Athar+’s commitment to empowering innovators and aspiring entrepreneurs to develop practical solutions that address real social priorities and enhance quality of life across our communities. By empowering future talent through Athar+, we are strengthening Abu Dhabi’s position as a regional hub for social entrepreneurship while advancing the Authority’s vision of fostering a culture of giving, participation, and measurable social progress.’’

Aligned with the objectives of the UAE’s Year of Family, the initiative also supports broader national efforts to strengthen family wellbeing, social resilience, and community cohesion through collaborative innovation and inclusive engagement.”

Through dedicated workspaces, expert mentorship, professional services, and tailored growth programmes offered by Athar+, participants will be supported in transforming ideas into prototype concepts while gaining access to opportunities within Abu Dhabi’s innovation and entrepreneurship ecosystem.

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QASHIO AND NEXA AI LAB LAUNCH PARTNERSHIP TO AUTOMATE FINANCE WORKFLOWS IN THE UAE

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Qashio, the UAE’s leading spend management platform, has partnered with NEXA AI Lab, the AI division of NEXA, one of MENA’s leading digital growth agencies, to help accelerate AI adoption across finance teams in the UAE through automation and AI-powered financial workflows.

As part of the partnership, Qashio and NEXA AI Lab will work together to support businesses in adopting AI tools that improve spend visibility, streamline manual processes, and make finance operations more efficient. The partnership will also include a free AI audit to help finance teams identify where AI can deliver immediate operational value and support broader adoption across the business. Both companies say the initiative is designed to move businesses from AI awareness to implementation, in line with the UAE’s national AI strategy targeting full public sector AI integration by 2031.

Amit Vyas, CEO of NEXA, comments: “AI delivers value when it is embedded directly into day-to-day workflows, rather than treated as a standalone concept. Finance is one of the clearest areas where this shift is already taking place, with businesses under increasing pressure to improve real-time decision-making. Through our partnership with Qashio, our goal is to help organisations identify where AI can be applied in practical, high-impact ways across financial operations.”

Armin Moradi, CEO of Qashio, said: “A global industry survey shows that 81% of financial institutions expect AI to be embedded in their core operations by 2030, and the UAE is one of the fastest-growing AI markets globally, setting a new baseline for competitiveness across the private sector. Our partnership with NEXA AI Lab is built to help close the gap between AI adoption plans and real execution, enabling enterprises and SMEs in the UAE to compete with the best in the world.”

Qashio has already integrated AI into its own financial workflows through features such as AI-powered receipt capture, which automatically extracts key information, including TRN, vendor names, and transaction data. The technology helps finance teams reduce manual data entry, save more than 4 hours each week, and maintain cleaner, more reliable financial records.

NEXA brings deep expertise in digital transformation and AI implementation across industries. Together, the two companies are focused on making AI accessible and measurable for businesses in the UAE. Both companies are already using tools like ConvoAI to improve access to data and provide instant support outside of working hours. Qashio is already leveraging NEXA AI Lab’s product offering. This reflects a broader shift towards always-on, AI-enabled operations.

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Standard Chartered Supports Pakistan’s First Panda Bond Issuance in Chinese Interbank Market

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Pakistan has successfully completed its inaugural Panda bond issuance in China’s interbank bond market, raising RMB 1.75 billion through a three-year transaction that marks the country’s first direct entry into China’s capital markets.

Standard Chartered (China) Ltd. Co acted as the only foreign bank serving as joint lead underwriter and joint book runner for the transaction, supporting Pakistan in broadening its international financing channels while strengthening financial connectivity between regional capital markets.

The issuance received strong support from multilateral development institutions, including the Asian Infrastructure Investment Bank (AIIB) and the Asian Development Bank (ADB), which together guaranteed 95 per cent of the bond’s principal and interest payments. The structure helped attract significant demand from Chinese banks, securities houses, and international financial institutions.

The transaction was reportedly more than five times oversubscribed, allowing Pakistan to price the bond at 2.50 per cent, the tightest end of the indicated pricing range.

Salman Ansari, Global Head, Capital Markets, Standard Chartered, described the issuance as a strategically important transaction that expands Pakistan’s access to global liquidity pools while demonstrating the growing relevance of regional capital markets within the international funding landscape.

The transaction also reflects the broader evolution of the Renminbi within global financial markets, as China continues expanding the role of its currency beyond trade settlement into cross-border financing and sovereign funding structures.

Jerry Zhang, Global Head of Banks & Broker Dealers and Head of Coverage, Greater China and North Asia at Standard Chartered, said the transaction highlighted the bank’s role in connecting international issuers with China’s domestic capital markets while also reflecting the continued internationalisation of the Renminbi.

The Panda bond market has increasingly attracted a wider range of sovereign, supranational, and institutional issuers in recent years as regional economies explore diversified funding channels and deeper access to Chinese liquidity pools.

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