Transfer Pricing- Oman

The current related party rules are included in Income Tax Law No. 28/2009, effective 1 January 2010. Broadly similar related party rules were also included in the old Income Tax Law, the Law of Income Tax on Companies of 1981. 

While the Oman tax law includes related-party provisions, there are no formal/detailed rules on transfer pricing documentation. However, the Oman Tax Authority expect that appropriate TP documentation will be made available under a tax audit or investigation.

Transfer Pricing in Oman

The current related party rules are included in Income Tax Law No. 28/2009, effective 1 January 2010. Broadly similar related party rules were also included in the old Income Tax Law, the Law of Income Tax on Companies of 1981. While the Oman tax law includes related-party provisions, there are no formal/detailed rules on transfer pricing documentation. However, the Oman Tax Authority expect that appropriate TP documentation will be made available under a tax audit or investigation.

  • Not Applicable at present

Not Applicable at present
The Sultanate of Oman introduced Country by Country Reporting (CbCR) requirements via Ministerial Decision 79/ 2020, applicable from the fiscal years beginning on or after January 1, 2020. In this regard, The CbCR requirements are applicable to companies that are tax residents in Oman and are members of any Multinational Group which has a consolidated group revenue of at least OMR 300 million. The CbCR is required to be filed no later than 12 months after the last day of the reporting fiscal year of the MNE group. On 7 July 2021, the Oman Tax Authority announced the suspension of the local filing requirement, which means that qualifying multinational enterprise (MNE) groups with an ultimate parent entity (UPE) resident outside of Oman will not be required to submit the CbC report in Oman in any situation until further notice. The other obligations i.e. notification requirements will continue to apply. CbCR Notification is applicable to all constituent entities to be submitted by the last day of the reporting period.

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For further information on transfer pricing please contact:

Mohammad Taher Shaikh [FCA, LL.B.]

Leader - Gulf Practice

20+ years, experience in International Tax and Transfer Pricing space.
Worked with A.F. Fergusson, KPMG, Ernst & Young and Deloitte wherein he served numerous Fortune 500 clients in different business space like consumer goods, automotive, IT and ITES. He did his masters in Law with Mumbai University and was part of the Tax Controversy Management Team at Deloitte.

Manoneet Dalal [LL.M.]

Leader - Global TP

20+ years, experience in Global Databases, Transfer Pricing Documentation & Compliance, Tax Controversy Management.

Worked with KPMG, Ernst & Young and Deloitte wherein he served numerous Fortune 500 clients. He did his masters in Law with Thesis on “Transfer Pricing Jurisprudence in different jurisdictions”.  He has successfully represented more than 100 complex transfer pricing litigation matters which are also published.

He has co-authored two books on Transfer Pricing.

  • A Taxmann Publication – Transfer Pricing Digest
  • A CCH Publication along with Deloitte – Transfer Pricing Law and Practice in India – A fine print analysis
Gyan Prakash Srivastava [MBA, LL.B.]

Leader - TP Policy

20+ years experience in Global Transfer Pricing Documentation, Litigation, BEPS compliance & advisory.

During his tenure with PwC & Deloitte he has worked for marquee clients.

Gyan specializes in assisting clients in developing cross border business models based on on-ground commercial facts and legal issues.

Saniya Abbasi [MBA]

TP Specialist – Gulf Region

Saniya Abassi is a Transfer Pricing expert with 7 years of experience in the Middle East, specializing in TP compliance, documentation, strategic planning, and advisory. She has extensive experience in profit attribution, BEPS implementation, and structuring cross-border transactions. Saniya has advised multinational companies across KSA, UAE, and Qatar on TP regulations, economic substance requirements, and Zakat compliance. She has extensive experience in benchmarking analysis and has prepared Local Files, Master Files, and CbCR, ensuring compliance with regional TP frameworks.

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