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Bahrain: The National Bureau of Revenue (NBR) extends record retention period to 10 years

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In brief

On 28 February 2024, the NBR notified taxpayers via email and an announcement on its webpage that the record retention requirement for Value-Added Tax has been extended from five to ten years. The initial five year record retention period for the 1 January 2018 – 31 March 2018 tax period (Q1 2018) would have lapsed as of 31 March 2024, but now has been extended to 31 March 2029.

The following documents are required to be retained by taxpayers, where applicable:

  1. Accounting books related to the Taxable Person’s work (all of the transactions according to their chronological and numerical order).
  2. Balance sheet and profit and loss account.
  3. Records of salaries and wages.
  4. Records of fixed assets.
  5. Inventory records and accounts (including quantities and values) at the end of any relevant Tax Period.
  6. A copy of Tax Invoices, credit and debit notes issued, and original Tax Invoices received by the Taxable Person.
  7. All customs documents relating to import and export transactions carried out by the Taxable Person.
  8. Additional records determined by the NBR.

It will be important for taxpayers to update their internal data and documentation policies and procedures to allow for the extended recorded retention period. The extension of the record retention period may signal a potential extension of the statute of limitation period, increasing the Tax Authority’s opportunity to undertake investigations and audits of the taxpayer’s historical tax submissions. As of now, we have not heard any mention of any change to the set statutory limitation period of five years.

To speak with us in relation to any tax matters or issues more generally, please contact one of the team members.

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Tina is a partner in the Firm's Dubai office. She advises leading corporations and public entities on VAT and transaction taxes (such as Real Estate Transaction Tax). Tina works across all sectors however she has deep experience in advising indirect taxes relating to financial services, property and construction, energy and government sectors. In addition to advisory work, Tina assists clients with tax authority audits, disputes, applications for clarifications. She also represents industry associations before the central banks and tax authorities.

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Reggie Mezu is a Senior Special Counsel in Baker McKenzie’s Dubai office. He focuses on corporate tax and has practiced tax for nearly 30 years, including in the UAE for 15 years. He has multi-jurisdictional and multi-disciplinary professional qualifications in law, accountancy and taxation.

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Trusha is an experienced senior associate in the Firm's Dubai office. She advises leading corporations and public entities on VAT and transaction taxes (such as real estate transaction tax).
Trusha is an emerging markets focused VAT executive. She has 11 years of experience in advisory, including a decade across Southern Africa and the Middle East, working on numerous cross-border tax transactions. Through her work advising sovereign entities, financial institutions and private investors, she has supported several IPOs, acquisitions, and the launch of next generation startups.
Trusha works across all sectors, and has deep experience in advising on indirect taxes relating to financial services, capital projects and service-based sectors. In addition to advisory work, Trusha’s focus remains on preparing clients to effectively communicate and manage tax affairs with the relevant authorities by way of tax clarification assistance, audit reviews and industry focused white-paper submissions. This allows her to effectively represent industry associations before the GCC central banks and tax authorities.

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