
DMTT and Pillar Two
Domestic Minimum Top-up Tax (DMTT) and Pillar Two in Oman
If your group’s consolidated revenue is EUR 750 million or more, your Oman entities must bear tax at an effective rate of at least 15%. Royal Decree 70/2024 introduced a domestic minimum top-up tax and an income inclusion rule for fiscal years starting on or after 1 January 2025. GSPU has built DMTT calculation models for GCC constituent entities and can take you from scoping to filing.
Is your group in scope? Your Oman entities are within the rules if the group’s consolidated revenue was EUR 750 million or more in at least two of the four preceding fiscal years, and they are not excluded entities.
Why it matters in Oman: the 15% corporate tax rate already meets the minimum for many companies. The top-up usually arises from tax holidays, free zone exemptions, the 3% rate or differences between accounting and tax profit.
How GSPU helps: scoping memo · effective tax rate calculation · safe-harbour review · registration and returns once the executive regulations set the procedure · coordination with your group’s Pillar Two adviser and GSPU’s UAE and Bahrain offices
The executive regulations set the procedure. [Confirm whether they have been issued, and add the deadlines.]
A tax holiday can bring your effective rate below 15% and create a top-up.



