Rules for Country-by-Country Reporting

Decision 79/2020

Issued on 17 September 2020 - (Effective after 1 January 2020)

Based on the Income Tax Law promulgated by Royal Decree 28/2009; and To the Royal Decree 34/2020 Ratifying the Convention on Mutual Administrative Assistance in Tax Matters;

In pursuant to the public interest,

It has been decided as follow:

Article One: The annexed rules shall be followed On Country-by-Country Reporting.

Article Two: This decision shall be published in the Official Gazette, and shall be effective for Reporting Fiscal Years beginning on or after 1 January 2020.

Issued on: 28/1/1441 Hijri Corresponding to: 17/9/2020

Saud Nassir Al Shukaily
Chairman of Tax Authority

Rules on Country-by-Country Reporting

Article 1 - Definitions

In application of this Decision, the words and phrases contained therein shall have the same meaning stipulated in the aforementioned Income Tax Law, and the following words and phrases wherever mentioned shall have the meanings next to them unless the context requires otherwise:

The Report

:

The Country-By-Country Report that shall be filed in accordance with the provisions of this Decision, the recommendations of the procedures for Transfer Pricing and Country-by-Country Reporting stipulated in Action 13 of the OECD Base Erosion and Profit Shifting Project, and other directives issued by that organization.

Designated persons

:

includes the following:

Group: a collection of enterprises related through ownership or control such that it is either required to prepare Consolidated Financial Statements for financial reporting purposes under applicable accounting principles or would be so required if equity interests in any of the enterprises were traded on a public securities exchange.
MNE Group: any Group that includes two or more enterprises the tax residence for which is in different jurisdictions, or includes an enterprise that is resident for tax purposes in one jurisdiction and is subject to tax with respect to the business carried out through a permanent establishment in another jurisdiction, and is not an Excluded MNE Group.
Excluded MNE Group: with respect to any Fiscal Year of the Group, a Group having total consolidated group revenue of less than (RO 300 million) three hundred million Rial Omani during the Fiscal Year immediately preceding the Reporting Fiscal Year as reflected in its Consolidated Financial Statements for such preceding Fiscal Year.