Article 124 outlines the procedure for claiming a foreign tax credit when no international treaty is in place (unilateral relief). Omani entities must apply within two years of paying the foreign tax. The Authority has six months to decide; silence thereafter is deemed an implied rejection, which can be disputed. If approved, the credit follows the limits of Articles 121 and 122. Crucially, this Article does not apply if a formal tax treaty (DTAA) exists, as treaty rules would then take precedence. This ensures Omani businesses operating in non-treaty countries still receive protection from double taxation.