On 29 October 2026, Oman issued Royal Decree No. 101/2026 (Decree) amending the Top-Up Tax Law promulgated by Royal Decree No. 70/2024. While the Decree takes effect from 2 November 2026, amendments to Articles 1, 2, 3, 5, 6, 7, 8, 9 and 3bis of the Top-Up Tax Law apply retrospectively, from the fiscal year beginning on or after 1 January 2025. Key highlights of the amendments are summarized below.
With key amendments applying from fiscal years beginning on or after 1 January 2025, in-scope MNE groups should assess the impact of the revised Top-Up Tax framework on their Oman operations. Immediate priorities include confirming the entities within scope, reviewing registration and Designated Filing Entity requirements, assessing reporting and payment readiness, and strengthening governance and record-retention processes. Groups benefiting from existing tax exemptions should also consider the potential Top-Up Tax implications. Businesses should continue to monitor the issuance of the Executive Regulations for further guidance on calculation mechanics, safe harbors and implementation requirements.
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