Article 12 provides a De Minimis Exclusion, allowing Filing Constituent Entities to report zero tax for a fiscal year under specific thresholds. To qualify, the MNE Group's average revenue in Bahrain must be less than EUR 10 million, and its average income or loss must be less than EUR 1 million over the current and two preceding years. Pursuant to Paragraph A, this requires an annual election by the Filing Constituent Entity. This exclusion does not apply to stateless entities or investment entities. This provision aims to reduce the administrative burden on smaller MNE operations while remaining consistent with OECD Pillar Two standards.