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Transfer Pricing
Oman

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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Oman TP Overview

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 Arm’s 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.

Regulatory Framework

Income Tax Law

Articles 125 and 125 bis provide the OTA with the power to adjust prices if they are not at arm's length.

Executive Regulations

Recently updated to include specific documentation standards for Master and Local files for taxpayers in Oman.

BEPS Action 13

Oman follows the three-tiered OECD approach: Master File, Local File, and Country-by-Country Reporting.

Documentation Pillars

▶ Master File

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.

▶ Local File

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.

▶ CbC Reporting

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.

Our Services in Oman

Documentation Sets

Preparation of OTA-compliant Master and Local Files.

AEOI Compliance

Assistance with CbCR notifications and reporting.

Risk Assessment

Identifying potential TP exposure under Omani Law.

Audit Defense

Support during OTA inquiries and technical justifications.

Expert Guidance in Muscat

Ensure your Omani operations are fully compliant with the latest OTA regulations.

Contact Oman Team

For further information on transfer pricing please contact:

Mohammad Taher Shaikh
Mohammad Taher Shaikh [FCA, LL.B.]

Leader - Gulf Practice

Manoneet Dalal
Manoneet Dalal [LL.M.]

Leader - Global TP

Gyan Prakash Srivastava
Gyan Prakash Srivastava [MBA, LL.B.]

Leader - TP Policy

Saniya Abbasi
Saniya Abbasi [MBA]

TP Specialist – Gulf Region