GTL Summary:

Cabinet Decision No. 39 of 2019, Article 59, places the burden of proof on the entity. It mandates that a company must demonstrate to the Authority that all transactions with linked entities strictly comply with the arm's length principle. Furthermore, the entity is required to provide sufficient and robust documentation to substantiate this claim. This proactive requirement ensures that businesses cannot simply assert compliance; they must maintain detailed records and analyses to actively prove their pricing strategies reflect independent market conditions to the Authority.

Document Type: ERS - Executive Regulations
Law: Income Tax Law 24 of 2018
Decision Number: executive-regulations-39-article-59
Year: 2019
Country: πŸ‡ΆπŸ‡¦ Qatar
Official Name: Article 59
Last updated at: 2026-02-23 12:13:40 UTC

SECTION 8 - TAX AVOIDANCE

Chapter 2 - Indirect Transfer of Profits between Related Entities

Article 59

An entity must demonstrate to the Authority that its transactions with linked entities comply with the arm's length principle and provide sufficient documentation to prove this.

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