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 pr…