At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-27. Tax authority: Department of Inland Revenue (DIR), Ministry of Finance. Summaries are simplified; check the linked official source before relying on them.
The law
#The Bahamas has no general corporate income tax and no transfer pricing law. The Ministry of Finance said in August 2024 that building an income tax system was a very large task and that businesses pay the business licence tax for now. So arm's length pricing matters in The Bahamas mainly through other countries' rules and through the new Domestic Minimum Top-Up Tax Act, 2024 (No. 58 of 2024, the DMTT Act). That Act does not set an arm's length rule. It copies the OECD GloBE Model Rules and applies them to Bahamas entities of very large groups, as a qualified domestic minimum top-up tax. The Bahamas has not adopted an income inclusion rule or an undertaxed profits rule.
Documentation
#There is no master file, local file or transfer pricing form. Country-by-Country reporting is the only transfer pricing style filing, under the Multinational Entities Financial Reporting Act, 2018 (No. 25 of 2018). A DMTT payer keeps its records in The Bahamas for 5 years after the latest tax year they cover (DMTT Act s. 20). CbC records are kept for 6 years.
Methods
#No transfer pricing methods are prescribed. No Bahamian law or guidance names the OECD Guidelines or an arm's length range. Pillar Two income is worked out under the GloBE Model Rules and the OECD commentary and guidance the Act lists, not under arm's length methods.
Penalties
#DMTT: the Act lets the Minister set penalties and interest (s. 16), but none were found published. The DIR says late filing or payment brings penalties and interest. A 2026 amendment adds penalty and interest on instalment shortfalls. Assessments can be appealed to the Tax Appeal Commission. CbC: fine of 10,000 dollars, 6 months in prison or both, or an administrative penalty of 4,000 dollars, plus 200 dollars a day while that is unpaid, and 5,000 dollars for known inaccurate information. Economic substance: 5,000 dollars plus 500 dollars a day for failing to report to the registered agent, and up to 300,000 dollars and striking off for failing notices. The law says dollars, and the Bahamian dollar is the local currency.
Pillar Two
#The DMTT Act took effect on 1 January 2024 and applies to fiscal years beginning after 31 December 2023. It does not apply to a fiscal year beginning before 1 January 2025 unless an IIR or UTPR applies to every Bahamas entity of the group for that year. So 2024 is in scope only where a foreign IIR or UTPR applied, and 2025 is the first year for the other groups. The group test is EUR 750m of revenue in 2 of the previous 4 years. Entities file a DMTT return or a GloBE Information Return on the One Tax Bahamas portal even if no tax is due. The return and payment are due 15 months after the fiscal year end, or 18 months for the group's Transition Year. The DIR moved filing (not payment) due before then to 30 September 2026. Two one-time notification forms (DMTT-24 by 31 March 2026 and DMTT-25 by 30 April 2026) have passed. From 1 July 2026 instalments are required, in periods still to be prescribed.
Other rules
#CbC: Bahamas entities of groups with USD 850m or more of revenue notify the Competent Authority (the Minister of Finance) by the last day of the group's fiscal year, and a Bahamas ultimate or surrogate parent files the report within 12 months. Economic substance: every entity under the Companies Act, IBC Act and partnership laws reports to its registered agent within 9 months after its fiscal year end, and the agent files on the ES portal. Weekends and holidays: s. 69 of the Interpretation and General Clauses Act (Ch. 2) moves a date that falls on a Sunday or public holiday to the next day that is neither, so only Sunday is a rest day and Saturday is not. The Public Holidays Act (Ch. 36) lists 1 January, 10 January (Majority Rule Day), Good Friday, Easter Monday, Whit Monday, Randol Fawkes Labour Day (first Friday in June), 10 July, the first Monday in August, 12 October, Christmas Day and 26 December, and a holiday that falls on a Sunday is observed on the Monday. National Heroes Day is kept on the second Monday in October in practice, which differs from the 12 October in the Act in some years. CRS and FATCA reporting are not covered here.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Country-by-Country notification to the Competent Authority Due by the last day of the group's reporting fiscal year (Multinational Entities Financial Reporting Act, 2018, s. 4). The entity says whether it is the ultimate or surrogate parent, or names the reporting entity and where it is resident. It is one-off, with changes sent by email by the end of the fiscal year in which they happen. It is made on the Bahamas CbCR portal run by the Ministry of Finance, and agents cannot make it for the entity. A failure is an offence, with a fine of 10,000 dollars, 6 months in prison or both, or an administrative penalty of 4,000 dollars (ss. 11, 15, 16). | Last day of the fiscal year (e.g. Dec 31, 2025) | Every constituent entity resident in The Bahamas of an MNE group with consolidated revenue of USD 850m or more in the preceding fiscal year. The Act uses USD 850m, not EUR 750m. | Multinational Entities Financial Reporting Act, 2018 (No. 25 of 2018), s. 4; The Bahamas CbCR Guidance Notes (10 December 2020) |
| 2 | DMTT pre-registration notification forms (DMTT-24 and DMTT-25) One-time forms sent to the DIR for each Bahamas Entity: DMTT-24 for a fiscal year that began in 2024 (due 31 March 2026) and DMTT-25 for one that began in 2025 (due 30 April 2026). An entity in scope for both years files both. Both dates have passed. The dates come from a DIR notice and form instructions, not from the Act, so they are not moved for weekends or holidays here. Submission is by email from the Adobe PDF form. | Date set by the DIR notice for the fiscal year that began in 2024 (form DMTT-24) or 2025 (form DMTT-25) (e.g. Apr 30, 2026) | Bahamas Constituent Entities (including joint ventures and permanent establishments) of MNE groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 fiscal years before the tested year (DIR FAQ). Purely domestic groups and standalone domestic entities are not covered. The Act applies to fiscal years beginning after 31 December 2023, but not to a fiscal year beginning before 1 January 2025 unless an IIR or UTPR applies to every Bahamas entity of the group for that year (DMTT Act s. 1(2)). | DIR: DMTT Notification Form Instructions (forms DMTT-24 and DMTT-25) |
| 3 | Economic substance report under the Commercial Entities (Substance Requirements) Act, 2023 (not a transfer pricing form) The entity gives its report to its registered agent (or the Compliance Commission if it has none) in time for the agent to report to the Minister of Finance on the ES portal within 9 months after the entity's fiscal year end (Act ss. 11 and 12; Guidelines v1.2, paras 4.7, 4.8 and 22.1). Contravening s. 11 costs 5,000 dollars plus 500 dollars a day, and the penalties for failing the test or a notice go up to 300,000 dollars and striking off. This is a tp-form kind only because no better kind exists. It is an economic substance filing, not a transfer pricing form. | 9 months after year end (e.g. Sep 30, 2026) | Every entity formed or registered under the Companies Act (including registered foreign companies), International Business Companies Act, Partnership Act, Partnership Limited Liability Act or Exempted Limited Partnership Act. Entities that earn income from a relevant activity must also meet the economic substance test. Investment funds and entities that are resident owned have lighter duties. | Commercial Entities (Substance Requirements) Act, 2023: Guidelines v1.2 (16 October 2025) |
| 4 | Country-by-Country report Due no later than 12 months after the last day of the reporting fiscal year (Act s. 5(3)), as an XML file in the OECD schema on the CbCR portal. The early 2019 date was removed by the 2019 amendment. Late or missing filing is an offence (fine of 10,000 dollars, 6 months in prison or both), or an administrative penalty of 4,000 dollars plus 200 dollars a day while that penalty is unpaid. Inaccurate information known at filing costs 5,000 dollars (ss. 15, 16, 18, 19). Records are kept for 6 years. | 12 months after year end (e.g. Dec 31, 2026) | Bahamas-resident ultimate parent entities, and surrogate parent entities, of groups at or above USD 850m. Other Bahamas entities do not file the report. | Multinational Entities Financial Reporting Act, 2018 (No. 25 of 2018), s. 5; Amendment Act, 2019 (No. 4 of 2019) |
| 5 | DMTT return or GloBE Information Return (on One Tax Bahamas) Every Bahamas Constituent Entity in scope files, whether or not tax is payable, either a GloBE Information Return with the notifications under Articles 8.1 and 9.4 of the GloBE Model Rules, or the prescribed DMTT return (s. 6(1) as amended from 1 July 2026). The period is 15 months after the fiscal year end, or 18 months for the Transition Year. The DIR moved every DMTT filing due earlier to 30 September 2026, so a 31 December 2024 year end (due 30 June 2026) became 30 September 2026. Transition Year rule: the Act gives 18 months for the group's Transition Year in The Bahamas and 15 months for later years (s. 7(1)). This tool uses 18 months only for year ends up to 30 December 2025, so a 31 December 2024 year end shows 30 June 2026 (the DIR's own example) and a 31 December 2025 year end shows 15 months (31 March 2027). That is the date for a group whose Transition Year was 2024 because a foreign IIR or UTPR applied to its Bahamas entities. If 2024 was not in scope for your group, the year beginning in 2025 is its Transition Year and the date is 18 months (30 June 2027 for a 31 December 2025 year end). | 15 months after year end (e.g. Mar 31, 2027) | Bahamas Constituent Entities (including joint ventures and permanent establishments) of MNE groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 fiscal years before the tested year (DIR FAQ). Purely domestic groups and standalone domestic entities are not covered. The Act applies to fiscal years beginning after 31 December 2023, but not to a fiscal year beginning before 1 January 2025 unless an IIR or UTPR applies to every Bahamas entity of the group for that year (DMTT Act s. 1(2)). | DIR: What is DMTT? FAQ (filing extension to 30 September 2026); DMTT Act, 2024 s. 6 as amended by the Amendment Act, 2026 (No. 25 of 2026), s. 2 |
| 6 | DMTT payment (top-up tax) Tax must be paid no later than 15 months after the last day of the fiscal year, or 18 months for the Transition Year (Act s. 7(1)). The DIR FAQ says payment is not extended: a 31 December 2024 year end had to pay by 30 June 2026. Payment is by wire to the Government of The Bahamas DMTT accounts in USD or BSD, and a payment notification is then made on the portal. Transition Year rule: the Act gives 18 months for the group's Transition Year in The Bahamas and 15 months for later years (s. 7(1)). This tool uses 18 months only for year ends up to 30 December 2025, so a 31 December 2024 year end shows 30 June 2026 (the DIR's own example) and a 31 December 2025 year end shows 15 months (31 March 2027). That is the date for a group whose Transition Year was 2024 because a foreign IIR or UTPR applied to its Bahamas entities. If 2024 was not in scope for your group, the year beginning in 2025 is its Transition Year and the date is 18 months (30 June 2027 for a 31 December 2025 year end). | 15 months after year end (e.g. Mar 31, 2027) | Bahamas Constituent Entities (including joint ventures and permanent establishments) of MNE groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 fiscal years before the tested year (DIR FAQ). Purely domestic groups and standalone domestic entities are not covered. The Act applies to fiscal years beginning after 31 December 2023, but not to a fiscal year beginning before 1 January 2025 unless an IIR or UTPR applies to every Bahamas entity of the group for that year (DMTT Act s. 1(2)). | DMTT Act, 2024 (No. 58 of 2024), s. 7; DIR: What is DMTT? FAQ |
| 7 | BIN and DMTT registration on the One Tax Bahamas portal Registration opened on 1 June 2026. The entity first gets a Bahamas Identification Number (BIN), then registers for the DMTT, and the return and payment notice are made through the same portal. The DIR pages and FAQ give no registration deadline, so register well before the return is due. The DIR said on 29 September 2026 that the Act does not require a named tax representative, so that reference was removed from the return. | See note | Bahamas Constituent Entities (including joint ventures and permanent establishments) of MNE groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 fiscal years before the tested year (DIR FAQ). Purely domestic groups and standalone domestic entities are not covered. The Act applies to fiscal years beginning after 31 December 2023, but not to a fiscal year beginning before 1 January 2025 unless an IIR or UTPR applies to every Bahamas entity of the group for that year (DMTT Act s. 1(2)). | DIR: What is DMTT? FAQ (June 2026) |
| 8 | DMTT instalment payments From 1 July 2026 a group that paid DMTT for the previous fiscal year pays that amount in instalments during the current year, in periods the DIR prescribes (new s. 7A). Any balance is due by the filing due date for that year. A shortfall against the instalment base can bring a penalty and prescribed interest. No prescribed instalment dates or rates were found, so no date is set. | See note | Bahamas Constituent Entities (including joint ventures and permanent establishments) of MNE groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 fiscal years before the tested year (DIR FAQ). Purely domestic groups and standalone domestic entities are not covered. The Act applies to fiscal years beginning after 31 December 2023, but not to a fiscal year beginning before 1 January 2025 unless an IIR or UTPR applies to every Bahamas entity of the group for that year (DMTT Act s. 1(2)). | Domestic Minimum Top-Up Tax (Amendment) Act, 2026 (No. 25 of 2026), s. 4 (new s. 7A) |
Official texts
#- Domestic Minimum Top-Up Tax Act, 2024 (No. 58 of 2024) and Amendment Act, 2026 (No. 25 of 2026) (No texts included. laws.bahamas.gov.bs says its legislation is under Government of The Bahamas copyright, may be reproduced if accurate and with the source and copyright status shown, and that the website may be used only for informational non-commercial purposes. That does not clearly allow reuse in a product, so nothing is quoted.)
- Multinational Entities Financial Reporting Act, 2018 (No. 25 of 2018); Commercial Entities (Substance Requirements) Act, 2023 (No texts included. These are published by the Ministry of Finance Competent Authority on taxreporting.finance.gov.bs, which gave no reuse licence, and the same government copyright terms are assumed to apply.)