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4.1. Domestic PE of a Foreign Entity

Unless a treaty provides otherwise, a non-resident is deemed to have a PE in Oman if the non-resident maintains in Oman a fixed place of business through which it carries on (all or part of) its business. Examples of a prior PEs include an office, a place of management, a sale outlet, a branch, a factory, a workshop, a mine, quarry or other place for extraction of natural resources, a building site, a construction or assembly facility, or a dependent agent. Effective fiscal year beginning 1 January 2017, the definition of PE was amended to provide that in case of a building site, place of construction, or assembly project, a PE would be deemed constituted if the project/ activity lasts for more than 90 days. Moreover, a service PE is deemed to arise where a non-resident performs consultancy or other services in Oman for a period or periods lasting 90 days or more in any 12-month period.