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May 15, 2026

Article 29 establishes the principle of joint liability for the payment of taxes and administrative fines. Under this provision, all Constituent Entities within the same MNE Group are jointly liable for the Tax Due and any fines imposed on their designated Filing Constituent Entity. Similarly, Joint Ventures and their subsidiaries share this liability. For flow-through entities that are not legal persons, joint liability extends to any non-natural person holding an ownership interest during the fiscal year. This ensures the Bahraini government can recover the 15% top-up tax from multiple sources within a multinational structure if necessary.

Chapter 5 - Administrative Provisions and Dispute Resolution

Article 29 - Joint Liability

The following shall be jointly liable for the payment of Tax and administrative fines:
1. Constituent Entities of the same Multinational Enterprise Group in respect of the Tax Due and imposed fines on the Filing Constituent Entity.
2. A Joint Venture or one or more of the Joint Venture Subsidiaries in respect of the Tax Due and imposed fines on the Filing Constituent Entity.
Where an Entity that is liable to Tax under the provisions of Paragraph A of this Article is a Flow-through Entity that is not a legal person, then any person, other than a natural person, who holds ownership interests in that Entity during the Fiscal Year or any period during that year shall be jointly liable for the payment of Tax and administrative fines.