GTL Summary:

Cabinet Decision No. 39 of 2019, Article 21, details the application of withholding tax (WHT) in Qatar. A 5% WHT applies to services performed or consumed within the state. It specifies that payments are deemed made after 12 months of entitlement. Exclusions include reinsurance, shipping, and specific interest on bank deposits or state bonds. Notably, interest paid by a permanent establishment to its head office is also exempt. This article provides a clear framework for when entities must withhold tax on payments to non-residents for services and interest.

Document Type: ERS - Executive Regulations
Law: Income Tax Law 24 of 2018
Decision Number: executive-regulations-39-article-21
Year: 2019
Country: 🇶🇦 Qatar
Official Name: Article 21
Last updated at: 2026-02-23 12:13:40 UTC

SECTION 2 - TAX CALCULATION

Chapter 2 - Withholding Tax

Article 21

  1. Amounts specified in Article 9(2) of the Law, paid by natural persons practicing an activity in the State, legal persons residing in the State, including ministries, other government agencies, public authorities and institutions, and permanent establishments in the State owned by non-residents, are subject to withholding tax.

    With the exception of amounts due to ministries, other government agencies, and public authorities, these amounts are considered actually paid after a maximum of twelve (12) months from the date of entitlement.

    Administrative and general expenses of the head office specified in Article 7 of these Regulations are not subject to withholding tax.

  2. Fees for services specified in Article 9(2) of the Law are subject to a five percent (5%) withholding tax on the total amount, without any cost deductions, if these services are wholly or partly performed in the State.

    A service is considered performed wholly or partly in the State if any work necessary for its completion is done within the State, including data collection, site inspection, and service completion, even if performed by another person on behalf of the taxpayer.

    Service delivery is not considered necessary for its completion. Services are considered performed in the State if they are used, consumed, or benefited from in the State, even if performed wholly or partly outside the State.

  3. The following activities are not considered services subject to withholding tax under Article 9(2) of the Law:

    1. Reinsurance

    2. Shipping and ticket sales

    3. Maritime transport of oil and derivatives, as well as related products

  4. The following interest payments are not considered subject to withholding tax:

    1. Interest on deposits in banks and financial institutions in the State;

    2. Interest on bonds and securities issued by the State, public authorities, and wholly or partially State-owned public companies;

    3. Interest on transactions, facilities, and loans with banks and financial institutions;

    4. Interest paid by a permanent establishment in the State to the head office or an affiliate outside the State.

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