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Document overview
Introduces top-up-tax rules for in-scope multinational enterprise groups under the minimum-tax framework.
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Scope and exclusions
Applies to
Applies only to groups and entities meeting the statutory scope and thresholds.
Limitations and exclusions
It is not a general rate increase for all Omani companies; excluded entities, transition rules and computations require separate analysis.
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Article-level text
Top-up Tax Law · Definitions
For the purposes of this Law, unless the context otherwise requires, the following words and expressions have the meanings set out beside them: 1. Top-up Tax: The Top-up Tax provided for in this Law. 2. Global Anti-Base Erosion Rules (GloBE Rules): The rules and guidance relating to countering base erosion and profit shifting issued by the Organisation for Economic Co-operation and Development. 3. Income Inclusion Rule (IIR): The rules included within the Global Anti-Base Erosion Rules. 4. Entity: Any legal person legally required to prepare separate financial accounts. This does not include units of the State Administrative Apparatus or other public legal persons. 5. Ultimate Parent Entity (UPE): An entity that directly or indirectly owns a controlling interest in any other entity and is not itself directly or indirectly owned by another entity through a controlling interest, or the main entity of a group. 6. Group means: (a) Multiple entities related through ownership or control, whose assets, liabilities, income, expenses and cash flows are either included in the consolidated financial statements of the Ultimate Parent Entity or excluded from those statements on grounds of size or materiality or because the entity is held for sale. (b) An entity located in one jurisdiction that has one permanent establishment, or more than one permanent establishment, located in other jurisdictions, provided that the entity is not part of another group. 7. Multinational Enterprise Group (MNE Group): A group that includes at least one entity or one permanent establishment not located in the jurisdiction of the Ultimate Parent Entity. 8. Constituent Entity means: (a) An entity within a group. (b) A permanent establishment of a main entity. 9. Financial Year: The accounting period for which the Ultimate Parent Entity of a Multinational Enterprise Group prepares consolidated financial statements, or the calendar year where consolidated financial statements are not prepared. 10. Regulation: The Executive Regulation of this Law.
Top-up Tax Law · Scope and revenue threshold
This Law applies to Constituent Entities that are members of a Multinational Enterprise Group whose revenue, expressed in Omani rials, equals or exceeds the equivalent of EUR 750,000,000 (seven hundred and fifty million euros) according to the consolidated financial statements of the Ultimate Parent Entity in at least two of the four Financial Years immediately preceding the Financial Year under assessment. Where the assessment establishes that one or more of the MNE Group's Financial Years taken into account for the purposes of the first paragraph of this Article is longer or shorter than 12 (twelve) months, the revenue threshold must be adjusted proportionately for each such Financial Year.
Top-up Tax Law · Excluded entities
This Law does not apply to the following entities: 1. Units of the State Administrative Apparatus and other public legal persons. 2. International organisations. 3. Non-profit bodies, such as associations, unions and private bodies of public benefit. 4. Pension funds. 5. An investment fund that is an Ultimate Parent Entity. 6. A real-estate investment entity that is an Ultimate Parent Entity.
Top-up Tax Law · Minimum level of taxation
Top-up Tax is imposed on the entities specified in Article 2 of this Law at a rate that brings the original tax imposed on them to the equivalent of 15% (fifteen per cent).
Top-up Tax Law · Entities liable to pay
The following are liable to pay Top-up Tax: 1. A Constituent Entity located in the Sultanate of Oman during any period within the Financial Year. 2. A Constituent Entity located in the Sultanate of Oman that is the Ultimate Parent Entity of a Multinational Enterprise Group and that, at any time during the Financial Year, directly or indirectly owns an ownership interest in a low-taxed Constituent Entity. 3. An Intermediate Parent Entity located in the Sultanate of Oman that, at any time during the Financial Year, directly or indirectly owns an ownership interest in a low-taxed Constituent Entity.
Top-up Tax Law · Qualified Income Inclusion Rule
Article 5 of this Law does not apply where a Qualified Income Inclusion Rule is required to be applied for the Financial Year in respect of either of the following: 1. The Ultimate Parent Entity of a Multinational Enterprise Group. 2. Another Intermediate Parent Entity that directly or indirectly owns a controlling interest in the Intermediate Parent Entity.
Top-up Tax Law · Partially-Owned Parent Entity
As an exception to Articles 5 and 6 of this Law, a Partially-Owned Parent Entity located in the Sultanate of Oman that, at any time during the Financial Year, directly or indirectly owns an ownership interest in a low-taxed Constituent Entity must pay tax equal to the portion allocated to that Constituent Entity. This does not apply where the entity referred to is wholly owned, directly or indirectly, by another Partially-Owned Parent Entity that is required to apply a Qualified Income Inclusion Rule for that Financial Year.
Top-up Tax Law · Low-taxed foreign Constituent Entity
Articles 5, 6 and 7 of this Law apply to a Parent Entity located in the Sultanate of Oman in respect of its low-taxed Constituent Entity that is not located in the Sultanate of Oman, in the manner prescribed by the Regulation.
Top-up Tax Law · Matters for the Executive Regulation
Subject to the provisions of this Law, the Global Anti-Base Erosion Rules and the relevant supporting documents issued by the Organisation for Economic Co-operation and Development, the Regulation must prescribe, in particular, the following: 1. The mechanism for calculating Top-up Tax and the provisions relating to safe harbours. 2. The controls governing the treatment of permanent establishments that are Constituent Entities as separate from the main entity and from the permanent establishments belonging to it. 3. The other rules, controls and procedures necessary to implement this Law.
Top-up Tax Law · Supplementary application of the Income Tax Law
Where a matter is not specifically provided for in this Law or its Regulation, the provisions of the Income Tax Law apply to the extent that they do not conflict with this Law or its Regulation.
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Official source
Royal Decree 70/2024 · Oman Tax Authority
September 20, 2026