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Stay ahead of Oman's evolving tax landscape. Ensure your intercompany transactions comply with the Oman Tax Authority (OTA) regulations and OECD standards.
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The Oman Tax Authority (OTA) has introduced formal Transfer Pricing regulations via the Executive Regulations of the Income Tax Law. These rules mandate that all transactions between related parties must be conducted at Arms Length.
Oman's commitment to the BEPS Action Plan 13 means that multinational groups operating in the Sultanate must maintain robust documentation and fulfill electronic filing obligations through the Tax Oman portal.
Articles 125 and 125 bis provide the OTA with the power to adjust prices if they are not at arm's length.
Recently updated to include specific documentation standards for Master and Local files for taxpayers in Oman.
Oman follows the three-tiered OECD approach: Master File, Local File, and Country-by-Country Reporting.
High-level overview of the global MNE group operations.
Taxpayers with related party transactions exceeding OMR 250,000 are generally required to maintain a Master File.
This file should contain information regarding the group's global business, intangible assets, and intercompany financial arrangements.
Detailed analysis of specific Omani entity transactions.
Mandatory for entities exceeding the OMR 250,000 threshold. It must focus on the functional analysis of the Omani taxpayer.
The Local File must be submitted to the OTA upon request and is essential for justifying the transfer pricing methods selected.
Filing for groups with revenue over OMR 300 Million.
In accordance with Decision No. 79/2020, MNE groups headquartered in Oman with consolidated revenue over OMR 300 million must file a CbCR.
Notifications must be filed by the last day of the reporting fiscal year through the Oman AEOI portal.
Preparation of OTA-compliant Master and Local Files.
Assistance with CbCR notifications and reporting.
Identifying potential TP exposure under Omani Law.
Support during OTA inquiries and technical justifications.
Ensure your Omani operations are fully compliant with the latest OTA regulations.
Contact Oman TeamFor further information on transfer pricing please contact:
