Oman Cross-Border Tax Guide 2026

Withholding Tax (WHT) — 10% Standard Rate

Oman imposes a 10% withholding tax on the following payments to non-residents (persons not resident in Oman for tax purposes):

• Dividends: Distributions by Omani companies to non-resident shareholders
• Interest: Interest on loans, bonds, and other debt instruments paid to non-residents
• Royalties: Payments for the use of intellectual property (patents, trademarks, copyrights, software) in Oman
• Management fees: Fees for management, technical, or consultancy services provided by non-residents

The payer (Omani entity) is responsible for withholding and remitting the tax to the GTA. Returns are filed monthly within 15 days of the month end. Failure to withhold exposes the payer to recovery of the tax plus penalties.

Double Tax Treaty (DTT) Relief

Oman has over 30 double tax treaties that generally reduce WHT rates below the domestic 10%. Key examples:

• Oman-UK DTT (2005): Dividends 5% (≥25% shareholding) / 10% (other); Interest 0%; Royalties 8%
• Oman-India DTT (2002): Dividends 10%; Interest 10%; Royalties 10%
• Oman-France DTT (2004): Dividends 5% (≥10% shareholding) / 10%; Interest 0%; Royalties 5%
• Oman-Germany DTT (2010): Dividends 5% (≥10%) / 10%; Interest 0%; Royalties 5%
• Oman-Netherlands DTT (2010): Dividends 5% (≥10%) / 10%; Interest 0%; Royalties 5%

To claim treaty benefits, the non-resident must apply for advance approval from the GTA (Form WHT-TP) and provide a certificate of tax residence from their home country.

Permanent Establishment (PE) Rules

A foreign company with a permanent establishment in Oman is subject to CIT at 15% on profits attributable to the PE. A PE includes a fixed place of business (office, branch, factory, construction site exceeding 6 months), a dependent agent with authority to conclude contracts, or the provision of services for more than 183 days in any 12-month period. Foreign companies without a PE in Oman are subject only to WHT on Omani-source passive income.

Transfer Pricing

Oman introduced transfer pricing regulations aligned with OECD guidelines (TP Rules issued under Royal Decree 2022). Requirements:

• Arm's length principle for all related-party transactions
• Master file and local file documentation for groups with related-party revenue exceeding OMR 5 million
• Country-by-country (CbC) reporting for groups with consolidated revenue exceeding OMR 100 million
• Transfer pricing disclosure in the annual corporate tax return

Penalties for non-compliance: 5% of the adjustment amount if the transfer pricing adjustment exceeds OMR 100,000. Documentation should be prepared contemporaneously and maintained for 5 years.

Foreign Tax Relief

Omani resident companies can claim a foreign tax credit for taxes paid abroad on foreign-source income. The credit is limited to the Omani CIT that would have been payable on that income (15%). Unused credits cannot be carried forward. Since individuals pay 0% in Oman, no foreign tax credit is available at the individual level (but individuals also owe no Omani tax on foreign income).