Transfer Pricing in Bahrain
Bahrain transfer pricing for the 2026 tax year. Bahrain has no general transfer pricing regime. This skill sets out the three rule sets that do exist: the arm's length adjustment, the five methods and the local file and master file under the Domestic Minimum Top-up Tax (DMTT) for multinational groups with revenue of EUR 750 million or more; country-by-country reporting under Ministerial Order No. 28 of 2021 (BHD 342 million threshold, notification, report, penalties); and the 46% hydrocarbon income tax, which has no arm's length clause. Use for "transfer pricing Bahrain", "Bahrain local file", "Bahrain master file", "CbCR Bahrain", "CbC notification Bahrain", "arm's length Bahrain DMTT", "related party pricing Bahrain" and APA or MAP questions. Out of scope: the full DMTT computation and other corporate taxes (bh-corporate-income-tax), residence, permanent establishment, withholding and treaty relief (bh-cross-border-tax), VAT (bahrain-vat).
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