Article 15 offers an exclusion for MNE Groups in the initial phase of their international activity. Tax is reduced to zero if the group operates in no more than six jurisdictions and the net book value of its tangible assets outside its 'Reference Jurisdiction' does not exceed EUR 50 million. This relief is available for a maximum of five years after the group first enters the scope of the OECD Model Rules. Pursuant to Paragraph A, this exclusion is only valid if no parent entity applies an Income Inclusion Rule (IIR). This provision supports the growth of emerging multinational enterprises within the Bahraini tax landscape.