The Organization for Economic Cooperation and Development (OECD) has confirmed the transitional “qualified” status of Oman’s DMTT and DMTT Safe Harbour. The continued recognition of this transitional status will depend on:
- The issuance of detailed Executive Regulations to Oman’s Top-up Tax Law
- Ongoing alignment with OECD guidance and peer review outcomes.
With Oman introducing Top-up Tax effective 1 January 2025, this recognition proves significant considering:
- It confirms that Oman’s DMTT framework is broadly aligned with the OECD’s Global Anti-Base Erosion (GloBE) Pillar Two Model Rules
- It secures Oman’s primary taxing rights over Top-up Tax arising on low profits within Oman
- It eliminates the need for additional top-up tax calculations for Oman in other jurisdictions where QDMTT Safe Harbour is satisfied, reducing the compliance requirements for in‑scope Multinational Enterprises
While implementation details of the Top-up Tax Law issued vide Royal Decree 70/2024 will be set out in the much-awaited Executive Regulations to Oman’s Top-up Tax Law, in‑scope, or potentially in‑scope, Multinational Enterprises should continue to:
- Assess scope and exposure
- Prepare data and processes
- Review structures and incentives
- Monitor developments and compliance obligations
In addition, the OECD has published a common understanding among implementing jurisdictions to provide GloBE Information Return filing relief where local portals or exchange relationships are not yet fully operational. For more details, refer to the OECD’s announcement on the release of this common understanding.
Our KPMG tax professionals remain available to help you navigate these developments, assess their impact on your organization, and support your readiness for compliance with Oman’s Top-up Tax requirements