Bahrain Ministerial Decision No. 106/2018 Concerning the Economic Substance Requirements was published by the Bahrain Minister of Industry and Commerce (MOIC), in the Bahrain Official Gazette on 27 December 2018 coming into effect as of 1 January 2019 for new licensees, companies that have added an activity to their commercial registration which falls within the ambit of Bahrain Ministerial Decision No. 106/2018, and companies that will acquire new assets of intellectual property.Bahrain Ministerial Decision No. 106/2018 can be considered to be the Bahraini Government's response the OECD Base Erosion and Profit Shifting (BEPS) project, specifically article 5 of Bahrain Ministerial Decision No. 106/2018 which relates to the countering of harmful tax practices. In addition to Bahrain Ministerial Decision No. 106/2018, the MOIC published (on 1 January 2020) detailed Guidance Notes which aim to clarify and re-confirm certain aspects of Bahrain Ministerial Decision No. 106/2018.