Clarification

On 7 July 2021, the Oman Tax Authority (OTA) announced a suspension of the requirement to file a CbC report with the OTA until further notice. (Click here for our previous alert).

Subsequently, the OTA issued an alert on 14 July 2021 clarifying that the above suspension is applicable only to those qualifying Multinational Enterprise (MNE) Groups with an Ultimate Parent Entity (UPE) resident outside Oman. Qualifying MNE Groups’ with 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.

Further, the alert explicitly clarified that the CbC notification requirement for Reporting Fiscal Year 2021 continues to remain applicable for all covered tax resident entities in Oman and is due for submission on or before 31 December 2021.

Our observations

The subsequent clarification issued on 14th July suggests that the pending bilateral exchange activation status of Oman with other countries may be the reason for announcing the suspension of CbC report filing for MNEs with an UPE resident outside of Oman.

For clarity, a summary of compliance requirements with respect to the current CbC rules in Oman are set out below: 

CbC requirement

MNE Group with UPE resident in Oman

MNE Group with UPE resident outside of Oman

Requirement to make a CbC notification for reporting fiscal year 2021 i.e., 1 January to December 2021

Yes, on or before 31 December 2021

Yes, on or before 31 December 2021

Requirement to file a CbC report for reporting fiscal year 2020 i.e., 1 January to December 2020

Yes, on or before 31 December 2021

Suspended until further notice

 

For further information on this development, please reach out to the team members below.