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