Bahrain - Anti-abuse provisions

Bahrain

Anti-abuse provision: Limitations on Benefits 

Article 10-12:

Notwithstanding the provisions of subparagraph (b) of paragraph 2, the Contracting State of which the company paying the dividends is a resident may tax the dividends at the rate under its domestic legislation in case the beneficial owner of the dividends is an individual and a resident of the other Contracting State as well as a resident of a third State. However, if the Contracting State of which the company paying the dividends is a resident, has concluded an Agreement for the avoidance of double taxation with the third state meant in the preceding sentence, the tax charged on these dividend payments shall not exceed the rate provided for dividends paid to individuals under that Agreement.