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June 26, 2026

This official Transfer Pricing Guide, issued by the National Bureau for Revenue (NBR) of Bahrain in June 2026, details the transfer pricing regulations applicable under the Domestic Minimum Top-up Tax (DMTT) framework (Decree-Law No. 11 of 2024). It establishes rules for ensuring that transactions between in-scope Multinational Enterprise (MNE) Constituent Entities, Joint Ventures, and branches align with the OECD's Arm's Length Principle. The guide defines the core comparability factors, outlines the five standard transfer pricing methodologies (CUP, RPM, CPM, TNMM, and PSM) with regional oil and gas examples, and sets explicit compliance requirements for maintaining both Local Files and Master Files.

DMTT Transfer Pricing Guide

Kingdom of Bahrain — National Bureau for Revenue

Version 1.0 | June 2026

1. Introduction

1.1 Purpose of this Guide
1.2 Overview of the scope of transfer pricing requirements

2. Arm’s Length Principle

2.1 General Remarks
2.2 Comparability Analysis
1. 2.2.1 Overview
2. 2.2.2 Contractual Terms of the Transaction
3. 2.2.3 Functional Analysis
4. 2.2.4 Characteristics of the Property Transferred or Services Provided
5. 2.2.5 Commercial and Economic Circumstances
6. 2.2.6 Business Strategies pursued by the parties
2.3 Transfer Pricing Methods
1. 2.3.1 Selection of the most appropriate transfer pricing method to the circumstances
2. 2.3.2 The Comparable Uncontrolled Price Method
3. 2.3.3 The Resale Price Method
4. 2.3.4 The Cost Plus Method
5. 2.3.5 The Transactional Net Margin Method
6. 2.3.6 The Profit Split Method

3. Transfer Pricing Documentation

3.1 Overview
3.2 Local File
3.3 Master File

Preface

This guide sets out general principles relating to the scope of the Decree-Law No. 11 of 2024 on 1 September 2024 which introduces the global minimum tax (in the form of a domestic minimum top-up tax (DMTT) for Multinational Enterprises (DMTT Law).

This guide is intended to provide general information only and contains the current views of the National Bureau for Revenue (NBR) on the application of the DMTT Law and Executive Regulations. The content of this guide is not intended to be exhaustive and does not cover every matter that would need to be considered by a Multinational Enterprise Group when assessing the impact of the DMTT.

This guide should be read in conjunction with the DMTT Law and Executive Regulations. The Multinational Enterprise Group may also refer to the Model Rules, Administrative Guidance and Commentary issued by the Organisation for Economic Cooperation and Development (OECD) to date for any additional information.

This guide is not a legally binding document and does not commit the NBR or any other person, including a Multinational Enterprise Group, in respect of any transaction or treatment. This guide does not provide binding interpretative directions and is not a substitute for obtaining competent advice from a qualified professional.

The rules relating to the DMTT in Bahrain are set out in the DMTT Law and its Executive Regulations are available on the NBR’s website, www.nbr.gov.bh .

Contents

Introduction

1.1 Purpose of this Guide