GTL Summary:

Cabinet Decision No. 39 of 2019, Article 57, introduces mandatory Master and Local Files for transfer pricing, following OECD formats. This obligation applies to resident entities linked to foreign entities that meet the Authority's revenue or asset thresholds. The files must be submitted within the tax return timeframe or as otherwise specified by the Authority. This alignment with OECD standards ensures that Qatari entities operating internationally provide standardized, detailed documentation regarding their global transfer pricing policies and specific local transactions to the tax Authority.

Document Type: ERS - Executive Regulations
Law: Income Tax Law 24 of 2018
Decision Number: executive-regulations-39-article-57
Year: 2019
Country: 🇶🇦 Qatar
Official Name: Article 57
Last updated at: 2026-02-23 12:13:40 UTC

SECTION 8 - TAX AVOIDANCE

Chapter 2 - Indirect Transfer of Profits between Related Entities

Article 57

A resident entity linked to others must submit both a master file and a local file in the format established by the OECD, unless the Authority adopts its own forms. The submission is to be made within the timeframe specified for returns or within any other timeframe set by the Authority. This obligation applies under the following conditions:

  1. The entity's total revenues or total assets, shown on its financial statements, meet or exceed the threshold set by the Authority.

  2. One of the linked entities is resident outside the state.

This obligation takes effect from the tax year beginning on or after a date specified by a decision from the President for this purpose.

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