Oman gazettes Pillar Two registration, return and enforcement amendments

Oman has published Royal Decree 101/2026, dated 29 October 2026, amending the Global Minimum Tax Law enacted by Royal Decree 70/2024. The decree and its amendment annex appear at printed pages 23–35 of Official Gazette 1672, issued on 1 November 2026. The original Arabic Gazette instrument and issue cover are available in public reproductions hosted by Qanoon, which is not the Ministry’s official publication service.

The annex supplies a much fuller statutory framework for registration, designated reporting entities, returns, payment and enforcement. It replaces Articles 1–3 and 5–9, while adding Article 3 bis and the Article 9 bis series. These are enacted amendments; their different application dates matter.

Two commencement rules

Decree Article IV applies the amendments to law Articles 1, 2, 3, 5, 6, 7, 8 and 9, together with new Article 3 bis, to the tax year beginning 1 January 2025 and subsequent tax years. The general commencement rule is the day after Gazette publication: 2 November 2026. That general rule governs the additional Article 9 bis provisions, including the new enforcement and penalty framework. The entire decree should therefore not be described as retrospectively operative from 2025.

What changes against the original law

The original 2024 law, Articles 2 and 4, already contained the €750 million, two-of-four-year revenue test and a 15% minimum-tax framework. Those headline features are not new November measures. The earlier Articles 5–8 addressed parent-entity charging positions, while Article 9 delegated detailed implementation to regulations. Our January 2025 article analysed that earlier text.

The replacement provisions now address administration expressly. Their significance lies in the statutory compliance architecture, rather than a newly announced headline rate. Article 9 continues to leave calculations, safe harbours and important entity treatments to regulations; publication of this annex does not itself establish OECD qualified status or the availability of a particular safe harbour.

Registration, returns and payment

Replacement Article 6 requires a constituent entity to apply for registration within 120 days from the start of its tax liability and to appoint and notify a designated reporting entity when registering. The Tax Authority can register an entity using available information. Procedures and forms remain subject to regulations.

Article 7 requires the designated reporting entity and constituent entity to submit the top-up tax return and GloBE Information Return, with required accounts and documents, within 15 months after the reporting financial year ends. Article 5 links payment to the return deadline. The annex does not contain an express 18-month first-year extension; groups should verify any applicable implementing or transitional measures before fixing their filing calendar.