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.
Interpretation and application must be checked against the official Arabic text and the current version.