As previously reported, Bahrain's National Bureau for Revenue (NBR) has published Decision No. (172) of 2024 issuing the Executive Regulations for Decree-Law No. (11) of 2024 Regarding the Implementation of Tax on Multinational Enterprises, the Domestic Minimum Top-Up Tax (DMTT). This includes new transfer pricing requirements in relation to the determination of the income or loss of a constituent entity in applying the DMTT rules, which include adjustments in relation to the arm’s length principle as specified in the regulations. In particular, Article 13 of the regulations provides that a constituent entity located in Bahrain shall make an adjustment to...