GTL Summary:

Cabinet Decision No. 39 of 2019, Article 10, regulates interest deductions on loans from related parties. It introduces a thin capitalization rule, limiting deductible interest to loans not exceeding three times the company's equity. The loan must contribute to the taxpayer's economic benefit and be supported by a formal agreement. Crucially, interest paid by a sole proprietorship to its owner is strictly non-deductible. These measures are designed to prevent tax base erosion through excessive interest payments to associated entities or internal owners within the State of Qatar.

Document Type: ERS - Executive Regulations
Law: Income Tax Law 24 of 2018
Decision Number: executive-regulations-39-article-10
Year: 2019
Country: πŸ‡ΆπŸ‡¦ Qatar
Official Name: Article 10
Last updated at: 2026-02-23 12:13:40 UTC

SECTION 2 - TAX CALCULATION

Chapter 1 - Taxable Income

Article 10
[4]

  1. Interest on loans and similar payments paid by the taxpayer to related parties, as defined by international accounting standards, are deductible up to the interest calculated on loans not exceeding three times the equity recorded in the accounting during the relevant accounting period, provided that the loan contributes to economic benefits for the taxpayer. This must be based on an agreement specifying the loan term and its purpose.

  2. [*][G16]

  3. Interest paid to the owner of a sole proprietorship for amounts deposited into their establishment is not deductible.

Footnotes

[4]Amended by Cabinet Decision 2023/3

GTL Notes

[G16]This paragraph was deleted, vide Amending Law No. 11 of 2022 and and Cabinet Resolution No. 3 of 2023. Prior to its deletion, the paragraph read as follows:

"2. Interest paid from a permanent establishment in the State to the head office or headquarters or to any entity affiliated therewith inside or outside the Statemay not be deducted."

There has also been a consequential amendment of numbering for the succeeding paragraph.

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