Through the Looking Glass
As we present the audio version of this edition of Through the Looking Glass, we invite you to experience these insights from the perspective of a global investor, shaped by first-hand observations of the transformation reshaping the Middle East and beyond.
Few regions today offer the same combination of ambition, pace of reform, strategic positioning, and appetite for partnership. From our vantage point at the crossroads of international capital and regional opportunity, this edition explores not only how markets are evolving, but where the next wave of investment value is being created.
Through the Looking Glass
Oman’s Trade Landscape
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Oman in 2026 looks different. A unified zones law, personal income tax, a maturing PPP framework, tighter corporate governance and a specialist investment court are changing how investors and lenders assess risk, structure deals and deploy capital. At the same time, disruptions in the Strait of Hormuz and the Red Sea have put Oman's ports and logistics infrastructure in the global spotlight — reinforcing its position as an alternative gateway to the Gulf and beyond.
Oman in 2026 looks different. A unified zones law, personal income tax, a maturing PPP framework, tighter corporate governance, and a specialist investment quarter changing how investors and lenders assess risk, structure deals, and deploy capital. At the same time, disruptions in the Strait of Hormuz and the Red Sea have put Amman's ports and logistics infrastructure in the global spotlight, reinforcing its position as an alternative gateway to the Gulf and beyond. Below, we set out the key developments and data points that boards, deal teams, and credit committees need to know. Vision 2040. Policy turned into law. Vision 2040 is no longer just a strategy document, it is being implemented. The 11th Five-year development plan, 2026 to 2030, drives a 20-year shift toward diversification, modernization, and fiscal sustainability. Non-oil growth is the headline metric with manufacturing, logistics, tourism, mining, fisheries and renewables as priority sectors. By end Q4 2024, non-oil activities reached OMR 28.32 billion in value added, up 4.1% year-on-year, while oil activities fell 4% and accounted for 32% of GDP. In 2025, non-oil GDP rose to OMR 28.70 billion, up 3.1%, compared with petroleum activities growing just 1.1% to about OMR 12.02 billion. Non-oil exports grew 7.2% between January and May 2025 to roughly OMR 2.7 billion. The 2025 economic performance bulletin records 3.39% real growth in non-oil activities through Q3 2025, driven by 9.11% growth in agriculture and fisheries, 1.80% in industrial activities, and 3.79% in services. The takeaway for investors. Major legislative moves, the new SEZ-free zone regime, PPP rollout, and personal income tax all tie back to stated Vision 2040 targets. They are not one-off reforms. The Ministry of Finance reports that 74% of Vision 2040 performance indicators show substantial progress, pointing to coordinated, top-down reform rather than piecemeal change. Geopolitics. Why Oman's location matters more than ever, you cannot assess Oman's investment landscape without looking at the geopolitics reshaping Gulf Maritime Trade. Red Sea shipping disruptions since late 2023 have kept Suez canal traffic roughly 60% below pre-crisis levels. Many carriers are rerouting around the Cape of Good Hope, adding around 1 million US dollars per voyage in fuel and 10 to 14 extra days in transit. The knock-on effect. An estimated 15 US dollars minus 20 billion a year in additional global supply chain costs, and 0.3 to 0.5 percentage points added to global food price inflation. On top of that, tensions around the Strait of Hormuz, through which roughly 20% of the world's oil moves daily, have added further uncertainty. In early 2026, regional hostilities disrupted straight transit, prompting MSC, Mesk, and CMSEGN to impose emergency surcharges and suspend new bookings for Arabian Gulf ports. War risk insurance premiums for vessels in the region have surged by 60% or more. This is where Oman's geography pays off. Its three main ports, Salala, Sohar, and Dukum, sit outside both the Strait of Hormuz and the Bab el-Mandeb threat zones. In March 2026, Sohar ports saw a 1,766% surge in ship destination change requests. Salala posted an 800% increase in route diversion. A Dubai Customs Green Corridor now links Oman and the UAE, and Qatar has designated Soha. Salala and Dukam as key alternative ports. Overland connectivity reinforces the trend. The UAE Iman Hafeat Rail Project, a US$2.5 billion joint venture that reached financial close in October 2024, will connect Soha port to Abu Dhabi and the UAE National Rail Network, creating a Rail Sea gateway into the wider GCC. Solala remains the world's second most efficient container port, 2023 World Bank / S and P Index, handling around 3.3 million TEUs in 2024. Duckham's cargo volumes grew 152% in the same year. For investors and lenders, this geopolitical context is not peripheral to the legal and regulatory analysis. It is what transforms Oman zone, tax and investment reforms from policy announcements into commercially significant structural advantages. Legal clarity around zones, customs, and investment is what turns Oman's physical geographic advantage into bankable structures. Investment environment, open but with clearer rules, Oman's foreign capital investment law, Royal Decree 50 of 2019 as amended, remains the backbone of its openness to foreign capital. It permits 100% foreign ownership in a wide range of activities, subject to a negative list and sectoral licensing, and offers a streamlined one-approval route for strategic projects above an OMR 10 million threshold. On the ground, investors continue to experience relatively straightforward incorporation of limited liability and single shareholder companies, backed by clear governance, accounting, and audit requirements. Foreign investment projects benefit from statutory protections against uncompensated expropriation and enjoy freedom to repatriate capital and profits. The numbers show this framework is being actively used. The Ministry of Commerce, Industry and Investment Promotion, MOSEEP, reports that the cumulative number of commercial registrations increased by 13.96% in 2024 to 441,773 registrations, compared with 2023. During H2 2024, 18,437 Amoni citizens were employed in wholesale and retail trade, construction and manufacturing under MOSEE programs. By February 2025, the Investor Residency Program had issued 3,407 golden residency cards to investors from more than 60 countries. FDI stock reached around 78.8 billion US dollars by end Q2 2025, up 12.8% year-on-year, with US. One recent development to note MOSIP Decision No. 411 2025 and now requires foreign-owned establishments and companies to employ at least one Amani national, registered with the Social Protection Fund, within a year of starting operations. Existing entities have transitional compliance mechanics. Non-compliant companies face administrative penalties. The broader direction is clear, more codified, enforceable rules, and less reliance on informal understandings. Investors who build compliant corporate, HR and governance structures from the outset will be best positioned. Corporate governance. Higher standards for enlisted companies. Alongside investment openness, Oman has tightened the governance baseline for corporate entities, particularly closed joint stock companies. Ministerial Decision 5 of 2025, issued by MOSEEP and effective 14 January 2025, promulgates the principles of corporate governance for closed joint stock commercial companies, SAOCs. The code largely aligns SAOC governance with standards applied to listed SAOGs, including requirements on board composition and independence board committees, such as audit and nominations slash remuneration, enhanced disclosure of related party transactions, and more prescriptive rules on convening and conducting general meetings. SAOCs are required to amend their articles of association within one year of the code's effective date to reflect the new principles. Complementary amendments to the commercial companies regulation under Ministerial Decision 245 of 2025, amending Ministerial Decision 146 of 2021, streamline corporate procedures and aligns secondary rules with the commercial companies law, Royal Decree 18 of 2019. For investors and lenders, the practical effect is that unlisted joint stock vehicles will increasingly resemble listed companies in their governance expectations, reducing key person and transparency risk in SAOC-based structures and providing a more reliable platform for pre-IPO and institutional participation. Zones and industrial policy. One law, multiple platforms. The biggest structural reform for corporates is the new law of special economic zones and free zones, Royal Decree 38 of 2025, effective 14 April 2025. It consolidates the Old Free Zones Law, Royal Decree 56 of 2002, and the Ducum SEZ framework, Royal Decree 119 of 2011, into a single regime under OPAS, which now oversees more than 20 SEZs, free zones, and industrial cities. What does this mean in practice? Three things. First, one framework, multiple platforms. Ducombe, Sohar, Salala, and other zones now sit under a single legal umbrella, reducing fragmentation and enabling cross-zone structuring. Second, codified incentives. Qualifying enterprises can access a tenure income tax exemption from the start of operations, renewable for up to 30 years total for strategic activities. Customs duty exemptions on zone imports and exports. 100% foreign ownership for operators, enterprises and real estate developers, exemptions from minimum capital requirements, subject to approvals, and the ability for developers to sell freehold real estate to non-armonies within zone projects. Third, digital processes. Governance, licensing, land allocation, and approvals run through a digital one-stop shop, with transitional provisions protecting existing operators as incentives until their current terms expire. OPAS reports that new investments in these zones exceeded OMR 1.4 billion in 2025, bringing total committed investments to roughly OMR 22.4 billion, a 6.8% increase compared with 2024. Ministry and Teara data show that FDI in the industrial sector grew 27.5% in Q1 2025 to OMR 2.749 billion, making industry the leading non-oil FDI destination and aligning with the Industrial Strategy 2040. For corporate and project finance clients, OMONIZones can now be treated as predictable, law-backed operating bases rather than bespoke exceptions. PPP and infrastructure. Moving from law to live projects, the PPP law, Royal Decree 52 of 2019, and its implementing regulations, Decision III of 2020, are now in the applied phase. PPP projects are exempt from the general tender law with a tailored process covering feasibility, pre-qualification, competitive tendering, negotiation, and financial close across power, water, waste, transport, education, and social infrastructure. The framework covers risk allocation, step-in rights, tariffs, change in law, termination and dispute resolution, and allows PPP tenors of up to 50 years, longer than traditional IPP slash IWPP terms. The Ministry of Finance now oversees PPPs following the dissolution of the original PPP authority. Both the PPP and privatization laws permit 100% foreign ownership of project and privatized entities. The government has identified at least 11 PPP projects and initiatives spanning transport and logistics, health, education, agriculture, fisheries, construction, and ICT, including the Salala Thumrat Truck Road, a 42 school bundle, diagnostic center management, fishery harbour development, and wind IPPs. A critical judicial development underpinning this framework is the law of the investment and commercial court, Royal Decree 35 of 2025, which establishes a specialized court mandated to resolve investment and commercial disputes within 90 days of registration, with a possible 45-day extension for complex cases. The court is supported by integrated judicial and civil registration systems to streamline evidence and enforcement. For investors and lenders, this offers a time-bound, technically focused forum for high-value disputes that can be factored into governing law and dispute resolution choices and built into bankability assessments. Tax. Corporate tightening and personal income tax ahead. Oman's income tax framework, based on the income tax law, Royal Decree 28 of 2009, as amended, has been steadily tightened. Corporate tax remains regionally competitive in rate, but practice is increasingly characterized by more detailed permanent establishment definitions, clearer deductibility rules, and stronger expectations around timely and accurate filing. The tax authority is investing in data-driven systems and interagency integrations to cross-check declarations, increasing the importance of robust transfer pricing and substance documentation, especially for cross-border groups and zone-based structures. The landmark development is the enactment of the Personal Income Tax Law, Royal Decree 56 of 2025, which introduces a 5% tax on individuals with annual gross income above OM of 42,000, effective 1st of January 2028. The threshold and determination of taxable income is calibrated in a manner which may result in the majority of residents falling outside the scope of the PIT regime. The law allows for certain deductions in relation to education, healthcare, zircot, charitable donations, and primary home interest. The PIT would require employers to withhold and remit tax unemployment income on behalf of employees. However, further detail in relation to the executive regulations are expected within a year of publication. The PIT law is published well ahead of implementation, giving boards time to adjust compensation, localization, and functional allocation across the GCC. It supports Vision 2040's goal of raising the tax to GDP ratio to around 15% by 2030 and 18% by 2040, in a measured, predictable way rather than through sudden, crisis-driven measures. For large multinationals, Oman implemented an income inclusion rule and domestic minimum top-up tax under the BEPS Pillar 2 framework from 1st of January 2025, Royal Decree 70 of 2024. Implementing regulations are awaited but are expected to follow the OECD model rules closely. Early modeling of effective tax rates and data readiness will be important. Employment, now a structural consideration, not just an operational one. Employment and workforce regulation is an increasingly important underlying part of the legal architecture shaping foreign investment in Oman, rather than a downstream operational concern. While the Omar labor law, Royal Decree 53 of 2023 as amended, continues to anchor employer-employee relations, workforce structuring is now more directly connected to licensing conditions, localization policy, and fiscal compliance, reflecting the broader vision 2040 emphasis on economic participation and private sector employment. Regulatory focus in this area is moving toward clarification and standardization, particularly in segments of the labor market that have historically operated with a degree of structural flexibility. Current policy signals suggest an intent to define boundaries and responsibilities more clearly, rather than to introduce abrupt or restrictive change. Within this context, forthcoming employment-related regulations are expected to address regulation of non-armoney manpower recruitment offices aimed at regulating labor recruitment offices engaged in the placement of basic/slash lower skilled manpower, including licensing requirements, scope of permitted activities, and compliance oversight. Regulation of human resources supply companies, particularly relevant for investors using manpower outsourcing, secondment or managed services models, and regulation of work in the oil and gas sector, covering workforce requirements, contractor obligations, and localization expectations. These sit alongside recent measures linking employment more directly to corporate permissibility, including localization-driven licensing conditions, minimum and money employment requirements for foreign-owned entities, and employer withholding obligations under the new PIT framework. The consistent theme: employment arrangements are increasingly treated as evidence of economic substance and regulatory alignment, not just an administrative function. For boards and deal teams, the implication is not immediate constraint, but the need for deliberate workforce design. Employment models, outsourcing structures, and compensation frameworks should be capable of accommodating regulatory clarification as it emerges, particularly where they intersect with localization planning, licensing continuity, and payroll-based compliance under the evolving tax regime. 9. FDI and growth. What capital is actually doing, official data show Immune's FDI stock more than doubling from about OMR 14.2 billion in 2020 to roughly OMR 30 billion in 2024, driven by reforms and sectoral strategies. By the end of Q1 2025, FDI stock reached OMR 30.61 billion, with inward investments of OMR 5.23 billion, up from OMR 4.11 billion in Q1 2024. By end Q3 2025, FDI stock had risen to OMR 30.95 billion, a 16.2% year-on-year increase, with inflows of OMR 4.32 billion in the first 9 months of 2025 compared with OMR 3.30 billion a year earlier, a 30.9% increase. Oil and gas exploration remains the dominant FDI destination, accounting for about OMR 24.9 billion of stock by Q3 2025, up 21.1% year on year, and approximately 81% of total FDI stock, with OMR 4.33 billion of inflows in the first 9 months of 2025. Manufacturing ranks second with around OMR2 billion. Real sector indicators are aligned. The Ministry of Finance reports 4.14% growth in non-oil activities in H1-2025 and the IMF project's real GDP growth of 2.9% in 2025 and 4.0% in 2026. As non-oil sectors, particularly industry and services, accelerate. What are investors actually doing? They are using SEZ slash free zone SPVs in Ducum, Sohar, and Salala as anchors for manufacturing, assembly, and regional distribution. They are bidding into PPPs using regional project finance templates adapted to Amani law. They are building corporate structures with real decision making and compliance capacity in Oman, not nameplate, presence. And they are drafting contracts with explicit change in law clauses, including references to future PIT and evolving PE tests. Boardroom questions for 2026. For regional boards, the question is no longer if Oman. But on what legal and fiscal terms? We're using the new SEZ slash free zones law optimally, zone-based SPVs, where we genuinely qualify for tax and customs relief, and onshore entities only where strategic? How do our existing ammonia structures align with stricter permanent establishment rules and enhanced compliance expectations? And do we need to uplift governance, documentation, and substance to avoid disputes or reassessments? How will the Pillar 2 rules impact our effective tax rate? And are we in a position to accurately calculate our Pillar 2 exposure and determine whether any reliefs or safe harbors may apply? For upcoming infrastructure, utilities or social projects, are we prepared to bid under the PPP law and the framework led by the Ministry of Finance with bankable risk allocation and financing structures that reflect the new legal architecture? How does the 2028 personal income tax law, 5% above OEM of 42000, affect our talent strategy and cost base for senior staff? And do we need to rebalance functions between Amman and other GCC centers? Within our GCC portfolio, is Amman positioned as a hydrocarbon plus industrial slash logistics and tourism node, and are our legal, tax and governance arrangements consistent with that targeted, sector-specific role? In light of the geopolitical disruptions reshaping maritime trade routes, are we factoring Amman's port and logistics infrastructure outside the Strait of Hormuz and Bab el-Mandeb into our supply chain resilience and regional distribution planning? How Al Tamimi and company can help. For corporate clients, the issue is no longer simply understanding what Amman's laws say today. The challenge is building cross-border structures that optimize the use of OMANI zones versus onshore Oman versus other GCC hubs, that align PPP risk allocation and security with what regional lenders will accept, that anticipate and accommodate corporate tax tightening and future PIT, and that allocate regulatory change, enforcement, and dispute resolution risk in a way that is consistent with wider GCC documentation and practice. Altamimi and Company is positioned to support on all four fronts. Our teams advise on corporate, tax, PPP, projects and disputes across the GCC and can help you design an Oman platform that fits within a coherent global structure rather than as a stand alone outlier.