It has been reported that the income tax treaty between the Sultanate of Oman and the Kingdom of the Netherlands has been approved by both the Omani and Dutch parliaments. As a result, the treaty will enter into force on January 1, 2012.

The treaty provides amongst others for the following features:

• 0% withholding tax on dividend payments if the receiving company (other than a partnership) owns at least 10% of the capital of the company distributing the dividends, or if the recipient is a qualifying government owned institution or pension fund; in all other cases, dividend withholding tax is reduced to 10%.

• 0% on interest payments;

• Maximum 8% on royalty payments; and

• Capital gains tax protection on transfer of shares.