DMTT and Pillar Two
Domestic Minimum Top-up Tax (DMTT Muscat) and Pillar Two 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.
Many multinational groups run their Omani operations from the capital. DMTT Muscat planning starts by listing every Omani constituent entity and confirming whether the group crosses the EUR 750 million threshold.
Is your group in scope for DMTT Muscat?
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.
Once scoped, compare accounting profit with taxable profit for each entity. Early comparison shows where a top-up may arise, so your Muscat finance team can plan well before year end.
Pillar Two Oman rules apply a global minimum tax of 15% to large multinational groups. Oman applies them through a domestic top-up tax and an income inclusion rule.
Why Pillar Two Oman Matters:
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.
GSPU prepares the numbers for your DMTT Muscat filings, so your team is not reconciling data at year end. Pillar Two Oman compliance depends more on data than on the headline rate. Deferred tax, permanent differences and exempt income all change the result, so early modelling avoids surprises.
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 Oman adviser and GSPU’s UAE and Bahrain offices.
A well-prepared DMTT Muscat file also helps group coordination, because your global adviser receives consistent, reviewed figures from one source.
Because the regime is new, many groups are unsure who owns the work. We recommend one owner and one calendar for Pillar Two Oman reporting.
There is no fixed deadline yet. Royal Decree 70/2024 gives the Chairman of the Oman Tax Authority the power to issue the executive regulations that set the registration and return procedure, and these have not been published. GSPU will confirm the dates as soon as the Tax Authority announces them. Meanwhile, groups can prepare by scoping their Oman entities and modelling their effective tax rate, so they can file quickly once the rules are out.
Possibly. A tax holiday can bring your effective rate below 15% and create a top-up. The result depends on your group’s scope and your entity’s profit calculation, so we recommend a quick review before the year-end close.
Please check one thing before publishing. Your draft says Oman introduced both a domestic minimum top-up tax and an income inclusion rule. EY’s summary of Royal Decree 70/2024 says the same. But PwC’s tax summaries (about 114 days old) describe only an income inclusion rule and say there is no indication of a domestic top-up tax. Please verify this against the decree or the Tax Authority before you publish the DMTT wording, since the whole article is built around it.
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