Oman rewrites top-up tax reporting and enforcement rules

Local compliance replaces parent-rule wording

The decree amends the law issued by Royal Decree 70/2024. Its replacement Articles 5–8 remove the earlier parent-level income-inclusion wording and address Omani payment, registration, returns and objections. This is a substantive rewrite, not simply a change to the law’s Arabic title. The unchanged Article 4 remains the charging provision; the amendment does not establish OECD qualified status.^[1][2]

Replacement Article 2 retains a threshold equivalent in Omani rials to EUR750 million of consolidated revenue in at least two of the four preceding financial years, with proportionate adjustment for non-twelve-month years. Excluded entities are separately defined; their data and revenue can still matter for reporting and the threshold. An ordinary corporate-tax exemption does not automatically exempt top-up tax.^[1][2]

Returns, corrections and evidence

Article 6 provides a 120-day registration period from becoming subject to tax and requires appointment of a designated reporting entity. Article 7 requires both the top-up tax return and Pillar Two information return within fifteen months after the reporting financial year-end, subject to the implementing framework. An electronic correction is required within thirty days of discovering an error or omission and before three years have elapsed from the original filing. These relative rules are not a newly calculated deadline for every existing group.^[1]

New Article 9 bis requires ten-year retention of supporting accounts and records from financial year-end, including for excluded entities within its terms. Additional provisions introduce inspection powers, offences and administrative penalties. Intentional misconduct, corporate responsibility and administrative breaches have distinct conditions; the text does not impose one automatic fine on every late filer.^[1]

Two commencement tracks

The decree generally operates from the day after Gazette publication, 2 November 2026. Specified replacement provisions and new Article 3 bis instead apply from the tax year beginning 1 January 2025 and subsequent tax years. Groups should reconcile local entities, designated-filer responsibility, existing registrations and reporting periods with the regulations before changing a compliance calendar or tax position.^[1][3]