Executive summary

Form DMTT-24, DMTT Notification, is a one-time notification for entities that fall within scope of the Domestic Minimum Top-up Tax Act 2024 (DMTT Act) for fiscal years beginning on or after 1 January 2024 and must be submitted to the Department of Inland Revenue (DIR) by 31 March 2026.

All Multinational Enterprise (MNE) Groups with operations in the Bahamas should review the new Form DMTT-24 requirements and assess potential administrative and compliance implications.

The Ministry of Finance introduced Form DMTT-24 (DMTT Notification) to facilitate preregistration under the DMTT Act. The form is intended to capture preliminary information from in-scope MNE Groups and their Bahamas entities so the DIR can identify scope, confirm the relevant fiscal year, gather contact and group-level information and prepare for subsequent DMTT registration processes.

Background

The purpose of the DMTT Act is to implement, by incorporating into local law and applying the Organisation for Economic Co-operation and Development (OECD) Pillar Two Global Anti-Base Erosion (GloBE) Rules, a domestic minimum top-up tax (DMTT) intended to qualify as a Qualified Domestic Minimum Top-up Tax (QDMTT) and for which the QDMTT Safe Harbour can be applied.

Under the DMTT Act, a 15% DMTT may be imposed on the profits of Bahamian Constituent Entities that are part of MNE Groups with annual consolidated revenue exceeding €750m, i.e., Pillar Two in-scope MNE Groups.

The DMTT Act is deemed in force as of 1 January 2024 and applies to fiscal years beginning after 31 December 2023, with specific transitional treatment for fiscal years beginning before 1 January 2025 if an Income Inclusion Rule (IIR) or Undertaxed Profits Rule (UTPR) applies.

Purpose and scope of Form DMTT-24

The DIR has released instructions for completing the preregistration notification, Form DMTT-24. The form is used to notify the DIR that an MNE Group — and its Bahamian Constituent Entities — will be in scope of the DMTT Act.

The form serves as an initial notification and administrative intake mechanism enabling the DIR to:

• Identify each Bahamian entity that is in scope of the DMTT Act for fiscal years beginning in 2024
• Identify the MNE Group and collect basic group-level information
• Confirm scope and the relevant fiscal year
• Prepare for DMTT administration and any follow-up data requests

A separate form must be completed for each Bahamian entity in an MNE Group for Pillar Two purposes.

Filing deadline

The 31 March 2026 deadline for submitting Form DMTT-24 is described as a one-time requirement for entities falling within scope of the DMTT Act for the fiscal year beginning on or after 1 January 2024.

Under the DMTT Act, the Ministry of Finance and DIR have confirmed that all Bahamian Constituent Entities that fall within scope of the DMTT Act must complete Form DMTT-24 by 31 March 2026.

The official DMTT-24 Notification Form and accompanying instructions are available through the DIR's website:

• Form DMTT-24 (Pre-Registration Notification) available here.
• Form DMTT-24 Notification Form Instructions available here.

Implications

Form DMTT-24 represents an important administrative milestone in implementing the Bahamas' DMTT regime. Although filing the form is framed as preregistration step, the form requires disclosure of key scoping data points — such as consolidated revenue, fiscal-year timing, UPE and GIR information, which will guide downstream DMTT process planning.

Actions for MNE Groups to consider, depending on their specific circumstances, include:

• Confirming whether any Bahamas Constituent Entities are within scope of the DMTT Act for the fiscal year beginning in 2024
• Ensuring alignment between DMTT-24 responses and country-by-country reporting (CbCR)/Pillar Two reporting data
• Identifying the authorized signatory and local contact responsible for ongoing administration
• Begin preparing supporting information in advance of the 31 March 2026 deadline