Oman: Clarification of suspension of country-by-country reporting

CbC reporting suspension is applicable only to those qualifying MNE groups with an “ultimate parent entity” resident outside Oman.

MNE groups with an “ultimate parent entity” resident outside Oman

The tax authority on 7 July 2021 announced a suspension of the requirement to file a country-by-country (CbC) report until further notice. Read TaxNewsFlash

Subsequently, the tax authority on 14 July 2021 issued a clarification that the CbC reporting suspension is applicable only to those qualifying multinational entities (MNE) groups with an “ultimate parent entity” resident outside Oman. Qualifying MNE groups having an Oman-based ultimate parent entity are still required to file the CbC report in Oman for the reporting fiscal year 2020 on or before 31 December 2021.

Further, the clarification explicitly provides that the CbC notification requirement for reporting fiscal year 2021 continues to apply for all covered tax resident entities in Oman and is to be filed on or before 31 December 2021.

KPMG observation

The subsequent clarification issued 14 July 2021 suggests that the pending bilateral exchange activation status of Oman with other countries may be the reason for the suspension of CbC reporting for MNEs with an ultimate parent entity (UPE) that is a resident outside of Oman.

KPMG has prepared the following table as a summary of compliance requirements with respect to the current CbC rules in Oman. 

CbC requirements

MNE group with UPE resident in Oman

File a CbC report?

MNE group with UPE resident outside of Oman

File a CbC report?

Requirement to submit a CbC notification for reporting fiscal year 2021 (1 January through 31 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 (1 January through 31 December 2020)

Yes, on or before 31 December 2021

Suspended until further notice


Read a July 2021 report prepared by the KPMG member firm in Oman

 

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