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June 26, 2026

Agreement between the Government of JAPAN and the Government of the Sultanate of OMAN for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

The Government of Japan and the Government of the Sultanate of Oman,

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

Have agreed as follows:

Contents

Article 1 - Persons Covered

Article 2 - Taxes Covered

Article 3 - General Definitions

Article 4 - Resident

Article 5 - Permanent Establishment

Article 6 - Income from Immovable Property

Article 7 - Business Profits

Article 8 - Shipping and Air Transport

Article 9 - Associated Enterprises

Article 10 - Dividends

Article 11 - Interest

Article 12 - Royalties

Article 13 - Capital Gains

Article 14 - Independent Personal Services

Article 15 - Income from Employment

Article 16 - Directors' Fees

Article 17 - Artistes and Sportspersons

Article 18 - Pensions

Article 19 - Government Service

Article 20 - Students and Business Apprentices

Article 21 - Other Income

Article 22 - Elimination of Double Taxation

Article 23 - Non-Discrimination

Article 24 - Mutual Agreement Procedure

Article 25 - Exchange of Information

Article 26 - Members of Diplomatic Missions and Consular Posts

Article 27 - Headings

Article 28 - Entry into Force

Article 29 - Termination

Protocol

Article 1
Persons Covered

This Agreement shall apply to persons who are residents of one or both of the Contracting States.

Article 2
Taxes Covered

  1. This Agreement shall apply to the following taxes:

    1. in the case of Japan:

      1. the income tax;

      2. the corporation tax;

      3. the special income tax for reconstruction;

      4. the special corporation tax for reconstruction; and

      5. the local inhabitant taxes

      (hereinafter referred to as "Japanese tax"); and

    2. in the case of the Sultanate of Oman: the income tax

      (hereinafter referred to as "Omani tax").

  2. This Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the Agreement in addition to, or in place of, those referred to in paragraph 1. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their respective taxation laws, within a reasonable period of time after such changes.

Article 3
General Definitions