We, Haitham bin Tariq, Sultan of Oman After reviewing the Basic Law of the State,

And the Income Tax Law issued by Royal Decree No. 28/2009, And based on what the public interest requires,

We have decreed the following:

Article One

The provisions of the attached Supplementary Tax Law on Entities Affiliated to Multinational Groups shall be implemented.

Article Two

The Chairman of the Tax Authority shall issue the executive regulations of the attached law, and shall also issue the necessary regulations and decisions to implement its provisions.

Article Three

Anything that contradicts the attached law or conflicts with its provisions shall be repealed.

Article Four

This decree shall be published in the Official Gazette and shall be effective from January 1, 2025.

Issued on: 29 Jumada al-Akhirah 1446 AH Corresponding to: December 31, 2024 AD

Haytham bin Tariq Sultan of Oman

Published in Official Gazette No. (1578) issued on January 5, 2025 AD.

Supplementary Tax Law on Entities Subsidiary to Multinational Groups Article (1)

In applying the provisions of this law, the following words and phrases shall have the meaning indicated next to each of them, unless the context of the text requires another meaning:

1. - Supplementary Tax:

   
   

   The supplementary tax stipulated in this law.

   
   

2. - Rules for Combating Global Tax Base Erosion:

   
   

   The rules and guidelines related to combating tax base erosion and profit shifting issued by the Organization for Economic Cooperation and Development.

   
   

3. - Income inclusion rule:

   
   

   The rules included in the rules for combating global tax base erosion.

4. - Entity:

   
   

   Any legal person legally obligated to prepare separate financial accounts, excluding units of the state administrative apparatus and other public legal persons.

   
   

5. - Ultimate parent entity:

   
   

   The entity that directly or indirectly owns a controlling stake in any other entity, and is not itself owned by a controlling stake in another entity directly or indirectly, or the main entity of a group.

   
   

6. - Group:

   
   

   A - Multiple entities related through ownership or control, whose assets, liabilities, income, expenses and cash flows are either included in the consolidated financial statements of the ultimate parent entity, or excluded from these statements on the basis of size or substance or because the entity is held for sale. B - Entities located in one jurisdiction and have one permanent establishment or multiple permanent establishments located in other jurisdictions, provided that the entity is not part of another group.

   
   

7. - Multinational Group:

   
   

   A group that includes at least one entity or one permanent establishment that is not located in the jurisdiction of the ultimate parent entity.

   
   

8. - Subsidiary entity:

A - An entity within a group.

B - A permanent establishment of a parent entity. 9 - Fiscal Year:

An accounting period for which consolidated financial statements are prepared by the ultimate parent entity of a multinational group, or the calendar year in the event that consolidated financial statements are not prepared.

10 - Regulations:

The executive regulations of this law. Article 2

The provisions of this law shall apply to the affiliated entities, members of a multinational group whose revenues in Omani Rials amount to or exceed the equivalent of (750,000,000) seven hundred and fifty million Euros according to the consolidated financial statements of the final parent entity during at least (2) years of the four fiscal years immediately preceding the fiscal year subject to assessment.

If the assessment proves that one or more of the fiscal years of the multinational group,

taken into account for the purposes of the first paragraph of this article, exceed or are less than (12) twelve months, the revenue limit shall be adjusted proportionally for each of those fiscal years.

Article 3

The provisions of this law shall not apply to the following entities:

1. - Units of the state administrative apparatus and other public legal persons.

   
   

2. - International organizations.

   
   

3. - Non-profit entities such as associations, unions and private bodies of public benefit.

   
   

4. - Pension funds.

   
   

5. - Investment fund that is considered a final parent entity.

6. - A real estate investment entity is considered a final parent entity. Article 4

The supplementary tax shall be imposed on the entities stipulated in Article 2 of this law, at a rate that would bring the original tax imposed on them to the equivalent of (15%) fifteen percent.

Article 5

The following shall be obligated to pay the supplementary tax:

1. - The subsidiary entity located in the Sultanate of Oman during any period during the fiscal year.

   
   

2. - The subsidiary entity located in the Sultanate of Oman, which is the ultimate parent entity of a multinational group, and which owns, at any time during the fiscal year, directly or indirectly, an ownership interest in a subsidiary entity subject to a low tax rate.

   
   

3. - The intermediate parent entity located in the Sultanate of Oman, which owns, at any time during the fiscal year, directly or indirectly, an ownership interest in a subsidiary entity subject to a low tax rate.

Article 6

The provisions of Article 5 of this law shall not apply in the event that the rule of including qualified income for the fiscal year must be applied, with respect to each of:

1. - The ultimate parent entity of a multinational group.

   
   

2. - Another intermediate parent entity that owns, directly or indirectly, a controlling interest in the intermediate parent entity.

Article 7

As an exception to the provisions of Articles (5, 6) of this Law, a partially owned parent entity located in the Sultanate of Oman that owns, at any time during the fiscal year, directly or indirectly, an ownership interest in a subsidiary entity subject to a low tax rate, must pay a

tax equivalent to the portion allocated to this subsidiary entity. This does not apply if the entity referred to is fully owned, directly or indirectly, by another partially owned parent entity that is committed to applying the qualifying income inclusion rule for that fiscal year.

Article 8

The provisions of Articles (5, 6, 7) of this Law shall apply to the parent entity located in the Sultanate of Oman in relation to its subsidiary entity subject to a low tax rate that is not located in the Sultanate of Oman