Worldwide transfer pricing reference guide 2014

Oman (continued)
Frequency of tax audit and transfer pricing scrutiny by the tax authority
The likelihood of an annual tax audit in general is high, as tax audits should be conducted on an annual basis. A review of transfer
pricing is a key components of an annual tax audit and therefore, its likelihood of review is also high. As there is no specific methodology
prescribed in the tax law, the appropriate transfer pricing methodology used is determined on a case to case basis. Accordingly,
the likelihood of the methodology being challenged in a transfer pricing audit is also high.
APA opportunity
There is no opportunity to conclude an APA.
The provision of advance rulings is not mentioned in the ITL; therefore, the tax department is not legally bound to grant an advance
ruling. However, as a matter of practice, the tax department has been responding to advance ruling requests. These responses are
binding on the tax department for that particular case and cannot be generally applied for any other case.
Expected reaction to OECD Report on BEPS
Since there are no transfer pricing guidelines prescribed by the tax law in Oman, the expected reaction of the Omani tax authorities to
OECD’s Report on BEPS cannot be stated with certainty. However, taxpayers should maintain appropriate documentation
(such as transfer pricing studies) to support value of transactions with related parties.
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