Oman amends its multinational-group top-up tax law through Royal Decree 101/2026

Oman Observer reports that Royal Decree 101/2026 amends the multinational-group top-up tax law introduced by Royal Decree 70/2024. The report states that some amendments apply to financial years beginning on or after 1 January 2025 and that the decree generally enters into force on the day following publication in the Official Gazette. The complete Official Gazette appendices were not available in the evidence reviewed for this edition.

The signal is material to multinational groups with entities or taxable presence in Oman because Pillar Two treatment can affect data collection, calculations, accounting, governance, registration and filing. The currently available report does not support a reliable description of each amended article, safe harbour, election, threshold, return, payment deadline or transition rule. A non-authentic English reproduction may assist discovery, but it cannot replace the Arabic Official Gazette text for legal reliance.

An affected group should preserve its current compliance position while opening a controlled gap review. The tax owner should obtain the authentic decree and appendices, map every amendment to the group structure and financial year, reconcile accounting and tax data, identify local and parent-company responsibilities, and obtain qualified advice before changing a calculation or filing. Horizon records the amendment and timing boundary but does not provide transaction-specific tax advice.