GTL Summary:

Cabinet Decision No. 39 of 2019, Article 63, targets indirect profit transfers between related entities. Taxable income must include any profits shifted through artificial price adjustments. This also applies to transactions with unrelated entities if they benefit from preferential tax regimes or are located in non-cooperative jurisdictions. Furthermore, the rule extends to transactions between an entity and its own permanent establishment in the state. By comparing these to hypothetical independent transactions, the Authority can re-calculate and tax the income that would have naturally been realized in Qatar.

Document Type: ERS - Executive Regulations
Law: Income Tax Law 24 of 2018
Decision Number: executive-regulations-39-article-63
Year: 2019
Country: 🇶🇦 Qatar
Official Name: Article 63
Last updated at: 2026-02-23 12:13:40 UTC

SECTION 8 - TAX AVOIDANCE

Chapter 2 - Indirect Transfer of Profits between Related Entities

Article 63

When calculating the tax due on the entity, the taxable income shall include the profits indirectly transferred to another related entity, whether through an increase or decrease in the agreed transaction prices between them, or by any other means. This determination is made by comparing the indirectly transferred profits to the profits that would have been realized if there were no relationship between the two entities or through other relevant comparisons.

The provisions of the previous paragraph shall also apply to transactions conducted between:

  1. A resident entity and another unrelated entity if:

    1. One of the entities benefits from a preferential tax regime.

    2. The other entity is resident in a non-cooperative state or territory, defined as one that has not signed an information exchange agreement with Qatar, with non-cooperative jurisdictions determined by a ministerial decision.

  2. An entity and one of its permanent establishments, if one operates in the state.

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