In this article we review Oman’s income tax laws from a Pillar Two perspective to highlight key issues to consider for MNEs with Omani subsidiaries or permanent establishments.
Whilst a five-year exemption could result in a jurisdictional GloBE ETR below 15% this is precisely the kind of activity that the substance-based income exclusion is targeted at. As such, even if there was an ETR below 15%, the effect of the substance-based income exclusion would be to reduce any top-up tax.
|Zone||Income Tax Exemption|
|Sohar Free Zone||25 years|
|Duqm Special Economic Zone||30 years|
|Salalah Free Zone||30 years|
|Al Mazunah Free Zone||30 years|
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