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July 17, 2026
Article 127 provides for 'Corresponding Adjustments' to ensure fairness after a transfer pricing audit. If the Tax Authority adjusts the income of one person (the first party) under Article 126, it may also adjust the taxable income of the other party involved in the same transaction. This prevents double taxation of the same profit; if one party's income is increased, the other party's related expense or income should be adjusted consistently. This maintains symmetry in the tax treatment of the transaction across both Omani taxpayers involved in the related-party deal.
Article 127
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