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

Before this announcement, the CbC report for the reporting period 1 January 2020 to 31 December 2020 (Reporting Fiscal Year 2020) was due for filing by qualifying multinational enterprises (MNEs) in Oman before the end of the current calendar year i.e., on or before 31 December 2021. This specific requirement has been suspended until further notice, as per the OTA’s announcement, dated 7 July 2021.

Notably, the CbC notification filing requirement for Reporting Fiscal Year 2021 continues to remain applicable and is due for submission on or before 31 December 2021. 

Brief background

CbC rules were introduced in Oman last year (September 2020), requiring all covered tax resident entities in Oman to file a CbC notification on or before the last date of the relevant reporting fiscal year.

These rules[1] also required the filing of the actual CbC report if the tax resident entity in Oman qualified as an ultimate parent entity (UPE), surrogate parent entity (SPE) or a local constituent entity (LCE) (as defined under the CbC rules), based on the template issued by the Organization for Economic Co-operation and Development (OECD) under Action 13 of the original BEPS Action Plan.

Click here for our previous detailed alert on the subject.

Our observation

As per the CbC rules, if Oman does not have a reciprocal bilateral exchange status[2] with the country in which the UPE or SPE of the MNE group is a tax resident, the LCE of the MNE group[3] is required to file a CbC report with the OTA in Oman.

Currently, Oman does not have an active bilateral exchange status with any country. In practical terms, this requires almost all qualifying MNEs in Oman to file their CbC report with the OTA. This holds true even in cases where the UPE or the SPE of an MNE is already filing their CbC report in their respective resident countries.

While the announcement does not provide any official reason for the suspension of the CbC report filing in Oman, it is expected to provide temporary relief to MNEs till the time Oman’s bilateral exchange status is activated with the other countries.

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

[1] As prescribed in OTA decision No. 79/2020

[2] Which allows Oman to also receive information from other jurisdictions

[3] The entity, which is selected as the reporting entity for Oman, in case the MNE group has multiple entities in Oman