This official Transfer Pricing Guide, issued by the National Bureau for Revenue (NBR) of Bahrain in June 2026, details the transfer pricing regulations applicable under the Domestic Minimum Top-up Tax (DMTT) framework (Decree-Law No. 11 of 2024). It establishes rules for ensuring that transactions between in-scope Multinational Enterprise (MNE) Constituent Entities, Joint Ventures, and branches align with the OECD's Arm's Length Principle. The guide defines the core comparability factors, outlines the five standard transfer pricing methodologies (CUP, RPM, CPM, TNMM, and PSM) with regional oil and gas examples, and sets explicit compliance requirements for maintaining both Local Files and Master Files.
DMTT Transfer Pricing Guide
Kingdom of Bahrain — National Bureau for Revenue
Version 1.0 | June 2026
Contents
1. Introduction
1.1 Purpose of this Guide
1.2 Overview of the scope of transfer pricing requirements
2. Arm’s Length Principle
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