CBAM and Oman

Oman sits third in the Gulf for relative Carbon Border Adjustment Mechanism exposure, with covered exports representing roughly 0.38 percent of GDP. Aluminium from Sohar leads, with steel and cement following. The definitive phase has applied since 1 January 2026.

Oman's position carries a forward-looking element the other Gulf states share less directly: hydrogen is one of the six sectors in scope, and the Sultanate's green hydrogen programme is aimed substantially at European offtake. For hydrogen the 50-tonne threshold falls away entirely — every volume triggers the obligation — which makes the question of who holds declarant status relevant from the first shipment.

What the definitive phase requires

Six sectors fall within scope today: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Article 25 of the CBAM Regulation provides that customs authorities allow the importation of CBAM goods by an authorised CBAM declarant, and that declarant purchases its certificates from the competent authority in the EU Member State where it is established. The status applies where cumulative annual imports exceed 50 tonnes of CBAM goods, with electricity and hydrogen counting from the first unit.

The first annual declaration covers calendar year 2026 and falls due by 30 September 2027. Certificate sales open on 1 February 2027 through the common central platform. Since 1 January 2026, EU import declarations carry a CBAM code in the additional reference field.

Aluminium today, hydrogen tomorrow

An Omani exporter setting up an EU entity now addresses two horizons with one structure. The existing aluminium and steel flows gain a declarant that imports in its own name, purchases certificates at the EU carbon price and holds the Article 23 licence deferring import VAT to the periodic return. The hydrogen projects coming into production find the European entity, the EORI number and the customs relationships already in place rather than assembled under deadline pressure.

For a producer whose commercial argument rests on low carbon intensity, presenting verified figures as the importer of record is considerably stronger than supplying them to a distributor who prices the advantage into its own margin.

Repatriating profit to Oman

The Netherlands and Oman maintain a double tax treaty, and Oman sits outside the Dutch list of jurisdictions that triggers the conditional withholding tax. For Omani parent companies this keeps the ownership chain direct: a Dutch BV held by the Omani group, with dividends flowing under treaty terms.

Setting up in the Netherlands

A Dutch BV is incorporated by notarial deed and registered with the Chamber of Commerce (KvK). Incorporation runs remotely by power of attorney, with the parent company holding the shares. After registration the BV obtains its VAT number and EORI number and applies for the Article 23 licence and the CBAM authorisation. The same entity then serves as your base for EPR registrations under the Packaging Regulation and for your European contracts.

Further reading: an EU entity for CBAM and fiscal representation and Article 23.

Frequently asked questions

Does CBAM apply to hydrogen exports from Oman?

Yes. Hydrogen is one of the six sectors covered in the definitive phase, and hydrogen sits outside the 50-tonne de minimis threshold, so all volumes fall within the obligation. Green hydrogen projects aimed at European offtake meet CBAM from the first shipment.

How exposed is Oman to CBAM?

CBAM-covered exports represent roughly 0.38 percent of Omani GDP, placing Oman third in the Gulf for relative exposure. Aluminium leads, with steel and cement following.

Does the Netherlands have a tax treaty with Oman?

Yes. The Netherlands and Oman maintain a double tax treaty, and Oman sits outside the Dutch list of jurisdictions that triggers the conditional withholding tax on dividends, interest and royalties to affiliated companies.

When do CBAM certificate obligations begin?

Certificate sales open on 1 February 2027 via the common central platform, and the first annual declaration covers calendar year 2026 imports with a deadline of 30 September 2027.