All individuals and businesses conducting an economic activity and making a VATable supply exceeding the mandatory threshold need to register for VAT.
Different rules apply depending on whether the individual or business is resident in Bahrain or non-resident.
Please refer to Section 3.1 of the VAT General Guide for further details on conducting an economic activity and Article 3.2 of the VAT General Guide for further details on non-residents.
If the value of your annual VATable supplies (standard and zero rated) exceeds the mandatory VAT registration threshold, you will need to register for VAT.
The mandatory registration threshold is the minimum value of actual supplies by which an entity becomes obliged to register for VAT purposes.
Please note that transitionary phasing applied to registration timelines depending on the size of business. Mandatory registration thresholds and effective dates can be found below:
As per Articles 33, 44, and 109 of the VAT Executive Regulations
The registration threshold is calculated based on either:
Annual VATable supplies for registration purposes are defined in Article 34 of the VAT Executive Regulations. Annual VATable supplies mainly cover VATable supplies that are either standard rated or zero rated. Hence, exempt supplies or sales of capital assets are not included in the calculation.
If your annual VATable supplies exceed the voluntary VAT registration threshold of BHD 18,750, you can voluntarily register for VAT.
You must, however, remain registered for a period of at least two years from the date of registration, unless you completely cease to carry out any business activities before the end of the two-year period. If you completely cease to carry out any business activities, you must provide sufficient evidence to the NBR.
As per Article 44 of the VAT Executive Regulations
When calculating your annual supplies, you should include the annual supplies for all branches owned by the same legal entity.
For completeness, a head office and its branch(es) are the same legal entity for VAT purposes. Similarly, sub-CRs falling under the same CR will be considered as the same legal entity.
The registration applications require information specific to the VAT applicant, including and not limited to:
As per Article 37 of the VAT Executive Regulations
Once you have submitted your registration application for VAT, NBR will review it. Once approved, NBR will issue the VAT payer with a VAT registration certificate. This will include details of your VAT registration number (VAT account number) and the date from which your VAT registration will take effect.
Your VAT account number (also referred as VAT registration number) will be a unique number that is given to you on your VAT registration certificate. You should include this on all VAT invoices, credit notes, and debit notes that you issue.
Your VRN will be a unique number and will be different to your excise duty account number, if relevant.
Your VAT registration certificate issued by the NBR will specify the date from which your VAT registration will take effect (effective date of registration).
As per Article 33 of the VAT Executive Regulations
Your VAT registration certificate should be placed in a visible place in your establishment. If you have several branches, a copy should be placed in a visible place in each branch.
As per Article 37 of the VAT Executive Regulations
As we have recently enhanced this functionality, you are advised to regenerate your certificate by proceeding to “My documents” section on your VAT account and using the “Re-print certificate” function on your existing certificate.
If there are any changes in the information that you have provided when you registered for VAT, you should notify NBR within thirty days from the date of the change. To do so:
As per Article 43 of the VAT Executive Regulations
If you are a non-resident person, you must register for VAT in Bahrain as soon as you start making VATable supplies in Bahrain where no one else is liable to account for the VAT due on your supplies. This is generally the case when you supply VATable goods or services in Bahrain to non-VAT registered businesses or end-consumers.
There is no minimum registration threshold for non-resident persons. Making a supply of BHD 1 to a non-registered customer will result in an obligation to register.
However, if the supplies are made to a registered business in Bahrain, you are not eligible for VAT registration.
If you are a non-resident registered with NBR, you may choose to appoint a VAT representative, duly approved by the NBR, to assist you in meeting your VAT obligations in Bahrain.
As per Article 36 of the VAT Executive Regulations
If you make exclusively zero-rated supplies and the value of your annual VATable supplies exceeds the mandatory VAT registration threshold, you have to register for VAT but you will be eligible for registration exception.
Should you wish to opt for this exception, you should submit an application to NBR who will provide their decision regarding the same. If you receive an approval for registration exception, you will not have any VAT related obligations such as filing VAT return in the future during each VAT period. This will also mean that you cannot recover any VAT that you incur on purchases and may therefore be an additional cost to the business.
As per Article 35 of the VAT Executive Regulations
If you do not register on time, you may be subject to penalties in accordance with Articles 60 & 63 of the VAT Law as well as sanctions for an offence that meets the conditions to be VAT evasion.
As per Articles 60 & 63 of the VAT Law
Two or more legal persons resident in Bahrain can apply to form a VAT group provided all conditions for ownership and control are met. Persons registered under the same VAT group will be treated as a single VATable person for VAT purposes. An establishment owned by an individual (i.e. a sole proprietorship) is not considered as a legal person and may not be a member of a VAT group.
For more information on who is eligible to form a VAT group and the conditions that must be met, please refer to VAT General Guide Section 3.4.
As per Articles 38 and 39 of the VAT Executive Regulations
If a joint venture has a commercial registration certificate, it can register as a separate legal entity with NBR using its own commercial registration number. However, if the joint venture does not have a commercial registration certificate, it should contact the NBR contact center and the registration section will reach out to them to assist them in the registration process.
A registered VATP can purchase goods or services from a person that is not VAT-registered. There will be no VAT charged on any purchases from a person that is not VAT- registered.
Transactions between branches within the same legal entity will fall outside the scope of VAT.
An applicant should apply for only one VAT account number for each individual or legal entity. The applicant must specify the commercial registration of the branch that he would like to designate as the branch to receive all communications from NBR for VAT purposes. In addition, the applicant must specify the commercial registration numbers of the remaining branches for compliance purposes. After approval, one VAT certificate will be issued for a legal entity and is applicable for all branches under the same legal entity. The certificate will have details of the designated branch only. Other branches will have to use the same VAT certificate. You would need to display the same VAT certificate in all branches and make sure to record the details of all your related and active branches in your registration form.
Applicants are encouraged to provide correct details at the time of profile creation request. However, they have an opportunity to change select registration application details by logging into their NBR account and accessing the section of “Update VAT payer details”, where they will be required to provide updates on their VAT registration information.
After amending the information, you must proceed to complete all next steps and submit the change request for NBR’s review. Please ensure you receive the change request acknowledgment from NBR as a confirmation of amendment.
In order to confirm that a supplier is registered for VAT with the NBR, you can use the VAT payer lookup tool on the NBR website. You will either need the VAT account number (also referred to as the VAT registration number) or the commercial registration number of the supplier to confirm whether or not they are registered for VAT. Please follow the link to access the VAT payer lookup tool.
Alternatively, if you have the supplier’s registration certificate, you can verify their registration status by scanning the QR code displayed on the VAT certificate. The QR scan will redirect you to the VAT payer lookup tool online which will display information on the supplier (if they are a VAT-registered business).
All branches of the same legal entity are considered to be registered as one VAT payer with the same VAT certificate and account number. The VAT certificate covers all the branches as long as they are under the same legal entity, therefore they must charge VAT when they sell VATable products.
Registration date is the date of approval of your VAT registration application. Effective registration date is the date from which your VAT obligations commence, i.e. the date from which you are required to start accounting for VAT on your VATable supplies. The effective registration date can be found on top of your VAT certificate.
If you have not heard back from NBR regarding the status of your application, please log into the portal and check for any communications you may have missed. For example, NBR may be requesting additional information in order for your application to be approved.
In case the application has been rejected, you will receive a clarification letter attached in the notification email.
A VATable person, or his VAT representative (where applicable) must maintain business records that evidence his supplies. These records may be in Arabic or English. The following are examples of records that should be maintained by a VATable person for VAT purposes:
NBR is regularly carry out inspections and audits and shall have access to all the above records on demand to examine the VAT due and verify compliance with VAT Law and Regulations.
As per Articles 56, 91 and 105 of the VAT Executive Regulations
This may be because the information you have submitted is incorrect. Please make sure the information you have submitted is correct or is exactly what has been requested by NBR in the clarification letter. If you are re-submitting your application, you will need to make sure at least one field has been changed for the application to be successfully resubmitted. If the issue persists, please contact us.
If you received a late registration penalty, it means you registered later than the mandatory registration date.
Please visit your account on NBR portal and access your certificate under “My Documents” tile. Please use the “Reprint certificate” function to update the certificate based on the new information. Kindly note that you will need to display this new certificate.
You can upload self-attested in-house financials, signed and stamped by your entity, if audited financial statements or financial reports are unavailable. However, you are required to submit all the financial documents as soon as they are available by updating your VAT payer details and submitting a change request.