GTL Summary:

Cabinet Decision No. 39 of 2019, Article 22, governs the interaction between domestic withholding tax and international double taxation avoidance agreements. Non-residents must submit a formal request to apply agreement-specific rates. If accepted, the Authority refunds overpaid tax. The article also specifies that withholding tax applies to payments made to non-resident companies even if they are owned by Qatari or GCC nationals. The Minister may issue special mechanisms and periodic circulars to guide the application of these international treaties, ensuring compliance with both local and global tax standards.

Document Type: ERS - Executive Regulations
Law: Income Tax Law 24 of 2018
Decision Number: executive-regulations-39-article-22
Year: 2019
Country: 🇶🇦 Qatar
Official Name: Article 22
Last updated at: 2026-02-23 12:13:40 UTC

SECTION 2 - TAX CALCULATION

Chapter 2 - Withholding Tax

Article 22

  1. In the case of an effective double taxation avoidance agreement, a non-resident person or their representative subjected to withholding tax according to the rates and conditions in Article 21 of these Regulations must submit a request to the Authority to apply the provisions of the agreement using the form prepared by the Authority. If the request is accepted, the Authority refunds the tax according to the refund procedures specified in Article 7 of these Regulations.

  2. The Authority issues periodic circulars regarding the application of certain double taxation avoidance agreements. The Minister may issue a decision specifying special mechanisms for applying withholding tax and double taxation avoidance agreements, outlining the conditions, procedures, and guarantees for applying these mechanisms.

  3. Withholding tax according to the rates and conditions specified in Article 21 of these Regulations applies to amounts paid to non-resident companies wholly or partially owned by Qatari nationals or nationals of Gulf Cooperation Council (GCC) countries.

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