Related party pricing, return disclosure and thin capitalisation review

We list your related party dealings, test pricing against arm's length, prepare the disclosure in the return and check related party interest against the 2:1 thin capitalisation limit.

OMR 750Yearly

For: Oman companies and branches with related party sales, purchases, services, loans or head office charges.

What we need from you

Related party list
Disclosure in the return
Intercompany agreements
Terms and pricing
Related party loan balances and interest
Thin capitalisation
Equity figures
Debt to equity ratio
Evidence of services received
Deductibility of charges
Group consolidated revenue
CbCR test

What we discuss

Does head office charge management or service fees?
Need evidence of benefit; WHT also applies
Are there related party loans?
Interest above the 2:1 debt to equity limit is not deductible
Is group revenue OMR 300 million or more?
CbCR notification
Do you keep a TP policy or benchmarking?
Strongly recommended given scrutiny

What we file

Related party review and thin capitalisation test
Equity OMR 500,000 allows related party debt of OMR 1,000,000; with OMR 1,400,000 borrowed, interest on OMR 400,000 is at risk
Complete related party disclosure in the return

What you get

Review note with risks and fixes
Disclosure schedule

The law

Income Tax Law (related party transactions): Related party dealings must be at arm's length and disclosed in the return; Tax Authority can recompute income Source
Income Tax Law (thin capitalisation): Debt to equity of 2:1 for deducting interest on related party loans Source
Oman country by country reporting rules: CbCR for groups with OMR 300 million revenue; local filing suspended in July 2021 for foreign parented groups Source

Questions people ask

Online payment in OMR is not open yet. Send us a message and an adviser for Oman confirms the scope and the fee before any work starts.