Country by Country Reporting (CbCR)

Country by Country Reporting (CbCR)

Country by Country Reporting (CbCR) Requirements in Oman

On 27 September 2020, Oman introduced Country by Country Reporting (CbCR) requirements vide Ministerial Decision 79/ 2020. As a member of the inclusive framework on Base Erosion and Profit Shifting (BEPS) project by the Organisation for Economic Cooperation and Development (OECD) and the G20, Oman has committed to implement the four minimum standards, including CbCR. The CbCR requirements apply to entities that are tax resident in the Oman and are part of an MNE Group with consolidated revenues equal to or exceeding OMR 300 million (approx. EUR 670 million / USD 780 million) in the financial year preceding the reporting year. The CbCR requirements are applicable for reporting years beginning on or after 1 January 2020. Accordingly, for the reporting year starting on 1 January 2020, the CbCR must be submitted latest by 31 December 2021.

As per the requirement, the Ultimate Parent Entity (UPE) of MNE Groups which exceeds the threshold of OMR 300 million and which are tax residents in Oman are required to file a CbC report within 12 months after the end of the reporting year concerned. There is an option to the MNE Groups to file the CbCR in Oman through a Surrogate Parent Entity (SPE) or local constituent entities subject to certain conditions.

Any constituent entity of an MNE Group that is tax resident in Oman, shall notify the Oman tax authority whether it is the UPE or designated as the SPE, no later than the last day of the reporting year of such MNE Group.

If such entity is not a UPE or SPE, it shall notify the Oman tax authority of the identity of the UPE or SPE, which will submit the CbCR on behalf of the Group and the tax residence of such UPE or SPE, no later than the last day of the reporting year of such MNE Group.

The content of the information to be reported for CbCR purposes as per the decision is aligned with the format put forth by the OECD. Currently, no penalties have been prescribed by the Oman Tax Authorities for non-compliance. It has been stated that the tax authority may use the CbCR for evaluating high level transfer pricing risks, and other BEPS and transfer pricing risks, as well as for the purposes of economic and statistical analysis.

For any CbCR related enquires and advisory services kindly get in touch with our expert consultants:

Aastha Rangan

Director – VAT & Transfer Pricing

M: +968 9136 1026

[email protected]


Ramya Annadurai

Director – Tax Advisory

M: +968 9215 4925

[email protected]


Antony Kallukaran

Director – Business Development

M: +968 9623 2268

[email protected]


Muhammad Faisal

Assistant Manager – VAT & Transfer Pricing

M: +968 7962 0028

[email protected]