Bahrain Tax Agency Posts Transfer Pricing Guide for Pillar 2 Minimum Top-Up Tax in English

The Bahraini National Bureau for Revenue June 7 posted online a guide, in English, on transfer pricing under the domestic minimum top-up tax (DMTT) law, aligned with OECD Pillar two rules for multinational enterprise (MNE) groups. Topics covered include: 1) applying the arm’s-length principle by requiring transactions to reflect independent market conditions and align profits with functions, assets, and risks; 2) requirements for functional and comparability analyses based on contractual terms, economic conditions, and business strategies; 3) confirmation of acceptable transfer pricing methods, with selection based on facts and reliability of comparables; and 4) details on documentation obligations, including preparation ...