GTL Summary:

Cabinet Decision No. 39 of 2019, Article 51, emphasizes the requirement for substantial economic activity and a real presence in Qatar for all projects. It prohibits residents from facilitating arrangements that generate profits without reflecting actual substantial activity within the state. This provision is a key part of Qatar's effort to align with global standards on economic substance, ensuring that entities operating in the state are legitimate businesses contributing to the economy rather than mere shells designed for profit shifting or tax minimization.

Document Type: ERS - Executive Regulations
Law: Income Tax Law 24 of 2018
Decision Number: executive-regulations-39-article-51
Year: 2019
Country: πŸ‡ΆπŸ‡¦ Qatar
Official Name: Article 51
Last updated at: 2026-02-23 12:13:40 UTC

SECTION 8 - TAX AVOIDANCE

Chapter 1 - Preventing Tax Avoidance

Article 51
[8]

[Every Qatari project must engage in substantial activity and have a real presence in the state. Residents in the state must not facilitate structures or arrangements aimed at generating profits that do not reflect substantial activity within the state.][G26]

Footnotes

[8]Amended by Cabinet Decision 2023/3

GTL Notes

[G26]This paragraph was amended, vide Amending Law No. 11 of 2022 and and Cabinet Resolution No. 3 of 2023. Prior to its amendment, the paragraph read as follows:
"In the application of the provisions of Article 33(2), Clause 1 of the Law, full competition shall be applied in accordance with the comparison free price method, which is the price of the goods or service that would have been applied if the transaction had been carried out between unrelated parties. In the absence of the necessary data to apply the comparison free price method, the taxpayer shall submit an application to the authority to apply any of the other pricing method approved by the Organization for Economic Cooperation and Development. In the absence of comparison elements specific to the situation under inspection, the GTA may be guided by comparisons with similar activities or other sources of income or any objective evidence available to the GTA."

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