GTL Summary:

Cabinet Decision No. 39 of 2019, Article 34, details the required components of final accounts, including financial position, cash flow, and equity change statements. It mandates specific schedules for depreciation, provisions, and transactions with related parties. Crucially, the auditor's report must confirm the audit was conducted to recognized standards and that the taxpayer's computer systems are secure against data manipulation. Furthermore, the individual auditing the accounts cannot be the same person who prepared them, ensuring professional independence and the integrity of the financial data submitted to the Authority.

Document Type: ERS - Executive Regulations
Law: Income Tax Law 24 of 2018
Decision Number: executive-regulations-39-article-34-bis
Year: 2019
Country: 🇶🇦 Qatar
Official Name: Article 34 Bis - Substantial Activity Requirements
Last updated at: 2026-02-23 12:13:40 UTC

SECTION 3 - TAX OBLIGATIONS

Chapter 2 - Tax Returns

Article 34 Bis
[9]

  1. Article 11 Bis of the Law applies to any project that meets the following criteria:

    1. More than 75% of the project's revenues in the previous two fiscal years come from the relevant incomes specified in clause (3) of this Article.

    2. More than 60% of the book value of the project's assets are located outside the state in the previous two fiscal years, or more than 60% of the project's relevant incomes are realized or paid through transactions with foreign entities.

    3. The project has relied on outsourcing for the management of daily operations and decision-making regarding key functions in the previous two fiscal years.

  2. Exceptions from clause (1) of this Article, the provisions of Article 11 Bis of the Law do not apply to the following projects:

    1. Companies or entities that have transferrable securities accepted for trading or listed on a regulated financial market.

    2. Licensed financial institutions.

    3. Projects whose main activity is owning shares in commercial operations in the state, provided that the beneficial owners are residents for tax purposes in the state.

    4. Holding companies resident for tax purposes in the state, provided that the partners, shareholders, or the ultimate parent entity are residents for tax purposes in the state.

    5. Projects that have at least five full-time employees exclusively conducting the income-generating activities relevant to the project.

  3. For the purposes of clause (1) of this Article, "relevant income" refers to income falling under any of the following categories:

    1. Income from immovable property.

    2. Dividend profits.

    3. Interest.

    4. Royalties.

  4. Projects meeting the criteria set out in clause (1) of this Article must disclose to the Authority, in the annual income tax declaration for each fiscal year, whether they meet the following minimum substantive activity indicators:

    1. Having a dedicated office in the state that is owned or exclusively leased by them.

    2. Having at least one active bank account in the state.

    3. One of the following indicators must also be met:

      1. At least one director of the project who is a tax resident in the state, authorized to make decisions concerning the activities generating relevant income for the project or concerning the project's assets, actively and independently uses the specified license on a regular basis, and is not an employee or director of any other non-associated project.

      2. A majority of the project's full-time employees are tax residents in Qatar.

Footnotes

[9]Added by Cabinet Decision No. 3 of 2023

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