Oman extends top-up tax law to financial-centre entities

The existing law is extended to the centre

Article 1 applies the law issued by Royal Decree 70/2024 to constituent entities in the Oman International Financial Centre. Article 2 requires publication in the Official Gazette and provides for effect on the following day. The decree is therefore an issued legal instrument, but no commencement date is stated here because its Gazette publication was not identified in the sources reviewed.^[1][2]

The existing group threshold and rate remain relevant

The extension matters to groups using the new financial centre because the top-up tax law applies to qualifying multinational groups. The threshold is consolidated annual revenue equivalent in Omani rials to €750 million in at least two of the four fiscal years immediately preceding the year under review. The original law provides for a 15 per cent top-up tax, subject to its exclusions and detailed calculation rules. Decree 105 does not create a separate OIFC rate or threshold.^[3][4]

Current reporting rules require separate application analysis

Royal Decree 101/2026 recently amended the underlying law. It provides for registration within 120 days after an entity becomes subject to the tax and requires a top-up tax return and Pillar Two information return within 15 months after the reporting fiscal year ends. Decree 105 states no separate OIFC filing timetable, transition mechanism or treatment for entities already operating in the centre.^[4]

Publication and transition remain open

OIFC groups should map local constituent entities, test the €750 million group threshold, identify the designated reporting entity and assess existing registration and return processes, while tracking Gazette publication of Decree 105. The official Gazette library showed issue 1673, dated 8 November, as the latest issue checked, which predates the decree. The interaction between the existing tax-year rules and the extension to OIFC, including any transition for current entities, remains to be confirmed from publication and implementation guidance.^[1][5]