Article 33 ^[18]

In case the taxpayer enters into agreements, transactions, or operations primarily aimed at avoiding the due tax, the Authority may withdraw the tax advantage obtained due to these agreements, transactions, or operations, according to the provisions of the Regulations.

The Authority may, in any of the cases stipulated in the previous Clause, take any or all of the following measures:

1. Reclassify the transaction if its form does not reflect its true substance.

2. Adjust the amount of tax due from the taxpayer or any other person related to the agreements, transactions, or operations stipulated in the first Clause of this Article.

[If a Qatari enterprise directly or indirectly participates in the management, control, or capital of a foreign enterprise, or a foreign enterprise directly or indirectly participates in the management, control, or capital of a Qatari enterprise, or the same persons directly or indirectly participate in the management, control, or capital of both a Qatari and a foreign enterprise, and conditions are imposed or established between the two enterprises in their commercial or financial relations that differ from those that would be established between two independent enterprises, any profits that would have accrued to any of the enterprises but for those conditions may be included in the profits of the Qatari enterprise and subjected to tax accordingly.

The entity is not entitled to any exemption or tax advantage unless its actual place of management is in the state.] ^[G40]