Oman

Businesses are taxed as separate entities, and the tax law does not recognise group taxation.

Transfer pricing

Transactions between related parties must be valued at arm’s length. There is no specific guidance on acceptable methods for determining an arm’s-length price.

Country-by-country (CbC) reporting

Oman introduced CbC reporting requirements applicable for reporting years beginning on or after 1 January 2020. Further, please note that, although the OTA announced the suspension of 'local filing' requirements for multinational groups headquartered outside Oman till further notice, other obligations (i.e. CbC notification requirements) will continue to apply.

Inter-company payments

All inter-company payments are scrutinised in detail to ensure that the profits are not transferred to avoid payment of tax.

Thin capitalisation

If the debt-to-equity ratio exceeds 2:1 in the case of related-party debt, interest on the excess debt is not deductible for tax purposes. This rule does not apply to banks and insurance companies, PEs of foreign companies, or proprietary (Omani owned) establishments.

Controlled foreign companies (CFCs)

There is no CFC regime in Oman.