Oman

On September 27, 2020, Oman introduced Country-by-Country Report requirements through the Chairman Decision of the Omani Tax Authority No. 79 of 2020 under the Income Tax Law issued by Royal Decree No. 28 of 2009 and Royal Decree No. 24 of 2020.

On July 7, the Omani tax authority suspended the requirement to file the Country-by-Country Report until further notice. All relevant entities operating in Oman must continue to comply with all other obligations.

Related Parties

According to Transfer Pricing, persons will be related parties if one thereof controls the other or a third party does over both.

Individuals will be related if one person is a family member of the other, up to the third lineage, i.e., from grandparents to grandchildren.

The control may be direct or indirect. The control will be given when a person is entitled to exercise control over the business activity and affairs of an enterprise. Specifically, it will be given when:

A person owns the majority of the capital or voting rights of the corporation.
A person is entitled to the majority of shares by the company.
A person is entitled to the majority of the company assets in the event of dissolution or cessation.

Transfer Pricing Methods

The Tax Department may consider Chapter II of the OECD Transfer Pricing Guidelines, as well as provide an appropriate basis for the pricing of related party transactions, but the former will not be required to comply with such OECD Guidelines.

Transfer Pricing Documentation

Whereas the Omani tax law includes provisions for related parties, there are no formal/detailed rules on the Transfer Pricing documentation. Conversely, the Omani Tax Authority expects the Transfer Pricing documentation to be available in the audit framework of a tax investigation.

The Oman Tax Authority issued Decision TA 79/2020, which introduces Country-by-Country Report rules for multinational groups operating in Oman.

Country-by-Country Report

The CbCR requirements apply to companies that are tax residents in Oman and members of any multinational group with a consolidated group income of at least OMR 300 million. The CbCR must be filed no later than 12 months after the last day of the preceding fiscal year. On July 7, 2021, the Omani Tax Authority announced the suspension of the requirement to file such a Report.

Penalties

Currently, TA Decision 79/2020 does not provide fines or penalties for non-compliance.

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