GTL Summary:

Cabinet Decision No. 39 of 2019, Article 53, mandates the 'arm's length principle' for all transactions between linked entities. This means pricing must mirror what would be applied between two independent parties. Entities must use reasonably available information to evaluate these prices at the time of the transaction or, at the latest, by the tax return filing deadline for that period. This principle is fundamental to preventing tax base erosion by ensuring that related-party pricing is not artificially manipulated to reduce the overall taxable income in Qatar.

Document Type: ERS - Executive Regulations
Law: Income Tax Law 24 of 2018
Decision Number: executive-regulations-39-article-53
Year: 2019
Country: 🇶🇦 Qatar
Official Name: Article 53
Last updated at: 2026-02-23 12:13:40 UTC

SECTION 8 - TAX AVOIDANCE

Chapter 2 - Indirect Transfer of Profits between Related Entities

Article 53

For tax calculation purposes, every entity must determine the prices of transactions with its linked entities based on the arm's length principle, using reasonably available information and evaluate those prices at the time of the transaction, and at the latest, by the time of filing the tax return for the accounting period in which the transaction occurred.

The arm's length principle means pricing applied between two independent entities.

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