Oman: Local Filling of CbCR Requirements
In July 2021, the Oman Tax Authority issued a clarification on the suspension of local CbCR requirements in Oman, as announced on 07 July 2021.
On 27 September 2020, Oman introduced Country by Country Reporting (CbCR) requirements vide Ministerial Decision 79/ 2020. The CbCR requirements are applicable for reporting years beginning on or after 1 January 2020. The requirements, broadly aligned to the OECD model legislation, are summarised below:
CbCR Threshold
Omani Riyal (OMR) 300 million (approx. EUR 670 million / USD 780 million) of consolidated revenue of the Multinational Group (MNE Group) in the preceding year.
Notification filing obligation
UPE/ SPE/ Other constituent entities, which are tax residents in Oman.
CbCR filing obligation
- Oman Tax Resident Ultimate parent entities (UPE) of MNE Groups;
- Option to file under Surrogate Parent Entity (SPE) filing mechanism, in case certain conditions are fulfilled;
- and Requirement for Oman entities other than UPE / SPE to file, in case certain conditions are fulfilled (i.e., local filing obligation - secondary filing).
Due dates
CbCR notification to be filed on or before the last day of the reporting year (i.e., 31 December 2020 for the year ended 31 December 2020) and CbCR to be filed within 12 months from the last day of the reporting year (i.e., 31 December 2021 for the year ended 31 December 2020)
Update
1. 7 July 2021
The Oman Tax Authority published an announcement suspending the requirement of local filing of CbCR until further notice. However, the other obligations i.e., CbCR notification requirements will continue to apply.
2. 14 July 2021
The Oman tax authority clarified the following:
- The suspension of the CbC reporting suspension is applicable only to those qualifying multinational entities (MNE) groups with a UPE resident outside Oman. Qualifying MNE groups having an Oman- based UPE are still required to file the CbC report in Oman for the reporting fiscal year 2020 on or before 31 December 2021.
- The suspension is applicable only to the local filing requirements (i.e., the filing of CbCR Reports). The requirement of submitting CbCR Notifications shall continue to apply.
CbC Requirements
1. CbC requirements
- CbC notification for reporting fiscal year 2021 (1 January through 31 December 2021)
- CbC report for reporting fiscal year 2020 (1 January through 31 December 2020)
2. MNE group with UPE resident in Oman
- On or before 31 December 2021
3. MNE group with UPE resident outside of Oman
- On or before 31 December 2021
- Suspended until further notice
