Qatar introduced Transfer Pricing rules in December 2019 as part of the Executive Regulations (ER) of the Income Tax Law No. 24 of 2018. The specific reporting requirements would be effective for fiscal years beginning on January 1, 2020.

The Qatari General Tax Authority (GTA) issued Decision No. 4 of 2020, which requires certain taxpayers with related party transactions to file a Transfer Pricing statement form with their tax return for 2020 and, in some cases, to file a Master File and Local File two months later.

Related Parties

Related entities are defined in Article 52 of the Income Tax Law Implementing Regulations with a broad interpretation.

It includes entities resident in Qatar and foreign entities with permanent establishments in Qatar.

Transfer Pricing Methods

The approved Transfer Pricing method in Qatar is the Comparable Uncontrolled Price (CUP). If another Transfer Pricing method is required to be applied, it will require the approval of the General Tax Authority (GTA) first.

The Arm’s Length Principle will be applied according to the Comparable Uncontrolled Price method, which is the price of the service or good applicable if the transaction was between unrelated parties.

Transfer Pricing Documentation

Transfer Pricing Statement

The Transfer Pricing Statement is stipulated in Article 56 of the Regulation Decree of the Income Tax Law, being a lighter version of the Master File and the Local Report to be filed by some entities before the General Tax Authority:

– The annual tax-free turnover of these entities or the total assets reported on their balance sheet is greater than or equal to QAR 10,000,000; and

– These entities are associated with other entities established in Qatar or abroad.

Two categories of information must be declared:

– General information on the group of related entities.

– Specific information on the reporting entity.

Local Report and Master File

Entities resident in Qatar must file a Master File and a Local Report if:

– The annual tax-free turnover of these entities or the total assets on their balance sheet is greater than or equal to QAR 50,000,000.

– These entities are associated with others established abroad.

Country-by-Country Report

The Country-by-Country Report is required through a notification to the ultimate parent company in Qatar with consolidated revenues of the multinational group exceeding QAR 3 thousand million in the previous financial year (approx. € 700 million)

Transfer Pricing Penalties

The GTA will monitor cases of non-compliance with the notification and filing requirements of the Country-by-Country Report and other statements and impose the penalties provided for in Article 24 (8) of the Income Tax Law (which may extend up to QAR 500,000).

Source: General Tax Authority (GTA)

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 Author:       Wolfgang Hartl
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