# Qatar transfer pricing v0.2

## Who this applies to

This Guide covers the ordinary income-tax regime administered by the General Tax
Authority (GTA). An entity with associated enterprises must price its transactions
at arm's length. Association follows international accounting standards, rather
than a percentage invented for this Guide. The rules cover assets, services and
other controlled transactions, including domestic transactions: Executive
Regulations (ER), arts. 52–54. Documentation thresholds do not exempt smaller
entities from the pricing rule.

Resident associated enterprises and Qatar permanent establishments (PEs) of
nonresident associated enterprises are within the declaration and master/local
file provisions of President's Decision 4/2020, arts. 2 and 6. These rules are not
the separate Qatar Financial Centre (QFC) regime. See the [official consolidated
law and ER](https://www.gta.gov.qa/assets/pdf/Income%20Tax%20Law%20EN%202024.pdf)
and [Decision 4/2020](https://www.gta.gov.qa/assets/pdf/Resolution%20of%20President%20of%20General%20Tax%20Authority%20No.%20%284%29%20of%202020.pdf).

Read that original decision with [Decision 10/2022](https://almeezan.qa/legislations/7e4d34ec-d133-43cf-b8fe-956a8169cf59),
which changes its filing deadline and penalty provision. The [current Arabic
ITL](https://almeezan.qa/legislations/d444f6ad-68b1-4244-af96-6bf9ee39e065)
and [ER](https://almeezan.qa/legislations/afee272e-4654-41c7-9e76-2b42f13c9b35)
control later amendments and translation conflicts; the 2024 English compilation
does not contain the subsequent penalty amendments.

## Rates, bands and thresholds

| Item | Amount or test | Tax year | Official source and provision |
|---|---|---|---|
| TP declaration | Entity/PE annual turnover **or** total assets at least QAR 10,000,000 | 2026 | [Decision 4/2020, art. 3](https://www.gta.gov.qa/assets/pdf/Resolution%20of%20President%20of%20General%20Tax%20Authority%20No.%20%284%29%20of%202020.pdf) |
| Transaction information in declaration | Transaction total **exceeds** QAR 200,000 | 2026 | [Decision 4/2020, art. 5(2)(b)](https://www.gta.gov.qa/assets/pdf/Resolution%20of%20President%20of%20General%20Tax%20Authority%20No.%20%284%29%20of%202020.pdf) |
| Master and local files | Turnover **or** total assets at least QAR 50,000,000, **and** one group entity resident abroad | 2026 | [Decision 4/2020, art. 7](https://www.gta.gov.qa/assets/pdf/Resolution%20of%20President%20of%20General%20Tax%20Authority%20No.%20%284%29%20of%202020.pdf) |
| Comparable financial data | Update annually; repeat database search every 3 years if business conditions are unchanged | 2026 | [ER art. 55](https://www.gta.gov.qa/assets/pdf/Income%20Tax%20Law%20EN%202024.pdf) |
| CbCR excluded group | Preceding-year consolidated group revenue **below** QAR 3,000,000,000; equality is not excluded | 2026 | [Finance Decision 16/2019, art. 1](https://almeezan.qa/legislations/14db8fef-545b-4c66-b34e-938f3755d541) |
| Ordinary income-tax rate used in examples | 10% of taxable income | 2026 | [Income Tax Law (ITL) art. 9](https://www.gta.gov.qa/assets/pdf/Income%20Tax%20Law%20EN%202024.pdf) |

Use the reporting entity's turnover/assets for Decision 4/2020. Do not substitute
group turnover. A government service summary describes a group-revenue test;
the legal decision's entity/PE test controls. The QAR 200,000 declaration-detail
test is not an arm's length safe harbour.

## The base

1. List each associated enterprise, its residence, agreements and controlled
   transactions. Reconcile payments and receipts to the ledger and accounts.
2. Describe functions performed, assets used and risks assumed. Identify actual
   conduct, rather than relying only on the contract: ER arts. 53–54.
3. Select and explain the most appropriate pricing method, tested party where
   relevant, comparables, assumptions and comparability adjustments. Decision
   4/2020 art. 10 requires these explanations; it does not prescribe an automatic
   cost-plus percentage. Keep evidence supporting any markup used.
4. Evaluate the price at the transaction date, no later than filing the period's
   return. Update comparable financial data and repeat searches as above.
5. Add profits indirectly shifted away from the entity to its taxable income,
   whether by understating receipts, overstating charges or another mechanism.
   ER art. 63 also extends the adjustment rule to an enterprise and its PE where
   one operates in Qatar, and specified dealings involving preferential regimes
   and non-cooperative jurisdictions. A complete documentation file does not
   prevent a pricing adjustment: ER arts. 59–63.
6. Apply the ordinary income-tax base, allowable deductions, exemptions and loss
   rules to the corrected result. Pricing a charge at arm's length alone does
   not establish its deductibility: ITL arts. 7–9. The examples assume a wholly
   foreign-owned ordinary taxable business, with no exemption or available loss.

All provisions in this section are in the [GTA consolidated law and
ER](https://www.gta.gov.qa/assets/pdf/Income%20Tax%20Law%20EN%202024.pdf) and
[Decision 4/2020, arts. 9–10](https://www.gta.gov.qa/assets/pdf/Resolution%20of%20President%20of%20General%20Tax%20Authority%20No.%20%284%29%20of%202020.pdf).

## Deadlines and filing

| Obligation | Deadline and content | Official provision |
|---|---|---|
| TP declaration | With the annual income-tax return, in the same form/manner and on the same due date | Decision 4/2020, arts. 4–5 |
| Ordinary annual tax return | Within 4 months after the accounting period ends, subject to an approved extension | ER arts. 29–30 |
| Master and local files | No later than 60 days after the final deadline for the reported year's income-tax return | Decision 4/2020, art. 8 as replaced by Decision 10/2022, art. 1 |
| GTA additional TP information request | Respond within the period specified under ER art. 56, up to 30 days from the request | ER art. 56 |
| Accounting/TP evidence | Keep for 10 years following the year concerned; longer while a dispute continues | ER arts. 36 and 62 |

The master file describes the group's structure, business, intangibles, finance
and tax positions. The local file documents the Qatar entity, each material
controlled-transaction category, agreements, analysis, accounts and the tie to
the financial statements: Decision 4/2020 arts. 9–10. File through the GTA's
Dhareeba service and retain submission acknowledgements. Sources: [law and
ER](https://www.gta.gov.qa/assets/pdf/Income%20Tax%20Law%20EN%202024.pdf),
[Decision 4/2020](https://www.gta.gov.qa/assets/pdf/Resolution%20of%20President%20of%20General%20Tax%20Authority%20No.%20%284%29%20of%202020.pdf)
and [GTA declaration service](https://www.sharek.gov.qa/en/articles/general-tax-authority/declaration-of-transfer-pricing/679b1f296798e422f45ac255).

For a 31 December 2026 year end, the ordinary declaration is due by 30 April 2027
and the master/local files by **29 June 2027**, absent a legally applicable
extension. Count 60 days from the final return deadline, not two calendar months
or the old fixed 30 June date. Recalculate from the applicable final deadline
where an extension applies. Source: [Decision 10/2022, art. 1](https://almeezan.qa/legislations/7e4d34ec-d133-43cf-b8fe-956a8169cf59).

### Country-by-country reporting is a separate test

[Finance Decision 16/2019](https://almeezan.qa/legislations/14db8fef-545b-4c66-b34e-938f3755d541),
arts. 1–5 and 8–9, replaces Decision 21/2018. For a non-excluded MNE group:

- A Qatar-resident ultimate parent submits the report within 12 months after
  the last day of the reporting fiscal year: arts. 2(1) and 5.
- A Qatar-resident ultimate parent notifies GTA by the reporting year's last
  day: art. 3(1), as applied by GTA Circular 10/2020, paragraphs 1–2.
- Circular 10/2020 states that a Qatar-resident non-parent constituent entity
  need not notify the reporting entity's identity/residence, regardless of
  whether its parent is resident in Qatar. Do not direct every subsidiary to
  submit a notice from the broad statutory wording alone. Determine any
  surrogate-parent role against the applicable provisions and commencement.
- The report gives jurisdiction-level revenue, profit, taxes, capital, earnings,
  employees, tangible assets and entity/activity identification, electronically
  in the prescribed format: art. 4. GTA identifies [Tabadol](https://tabadol.gta.gov.qa/)
  as its information-exchange portal.
- Arts. 2(2)–(3) and 3(2), concerning local subsidiary filing, surrogate relief
  and reporting-entity identification, start only for a fiscal year designated
  by a President's decision: art. 8(2). Do not activate them merely because
  they appear in the law. For current application, the
  [OECD 2026 Qatar peer review](https://www.oecd.org/en/publications/country-by-country-reporting-compilation-of-2026-peer-review-reports_353cb719-en/full-report/qatar_b342d28e.html)
  records local filing as suspended, Qatar's confirmation that its rules are
  unchanged and effectively applied, and its non-reciprocal status without
  local filing. Read that jurisdiction-confirmed implementation evidence with
  art. 8(2) and GTA Circular 10/2020: an ordinary non-parent subsidiary is not
  directed to file a CbC report merely from the uncommenced statutory clauses.
  This conclusion rests on positive current implementation evidence, not failure
  to locate a commencement decision. The peer review also records surrogate-parent
  filing as permitted; a voluntary surrogate role requires its own eligibility
  and exchange analysis and is not a mandatory local-subsidiary filing rule.

For a calendar 2026 Qatar ultimate parent, these statutory dates are
31 December 2026 for the notification and 31 December 2027 for the report.
The notice is electronic through Dhareeba under [Circular 10/2020, pp. 1–2](https://www.gta.gov.qa/assets/pdf/Circular%20of%20the%20GTA%20President%20No.%20%2810%29%20of%202020.pdf);
QFC coordination is separately specified there. See also [GTA information
exchange](https://www.gta.gov.qa/en/agreements-topics/automatic-info-exchange).

## Penalties and interest

| Breach | Financial penalty | Official provision |
|---|---|---|
| Late ordinary income-tax return | QAR 500/day, capped at QAR 180,000 | ITL art. 24(1) |
| Late tax payment | 2% of due tax per month or part, capped at that tax | ITL art. 24(2) |
| Master/local-file submission duty breached | QAR 20,000 | Decision 4/2020 art. 11 as replaced by Decision 10/2022 art. 2, applying ITL art. 24(3) |
| Audited-account/accounting-book breach | QAR 30,000 | ITL art. 24(5) |
| Specified failure to keep complete/accurate required records, provide them on time or avoid premature destruction | QAR 30,000 | ITL art. 24(10), added by Law 22/2024 art. 3 |
| Requested information/document not supplied on time | QAR 200 per missing item/document, capped at QAR 72,000; includes other persons possessing/controlling it | ITL art. 24(11), added by Law 22/2024 art. 3 |
| Incomplete/incorrect information supplied | QAR 100 per item, capped at QAR 10,000 per registration, return, notice or application; where this causes incorrect tax, the provision imposes 50% of the resulting unpaid tax | ITL art. 24(12), added by Law 22/2024 art. 3 |
| Late or incomplete/incorrect CbCR notification | QAR 100 per day late or per incomplete/incorrect item, as applicable | GTA Decision 7/2019 art. 2 |
| Late or incomplete/incorrect CbC report | QAR 500 per day late or per incomplete/incorrect item, as applicable | GTA Decision 7/2019 art. 3 |

Sources: [current ITL art. 24](https://almeezan.qa/legislations/d444f6ad-68b1-4244-af96-6bf9ee39e065),
[Law 22/2024 arts. 3 and 5](https://almeezan.qa/legislations/3643a42a-bdc0-4546-95d6-975557616a1b),
[Decision 10/2022 art. 2](https://almeezan.qa/legislations/7e4d34ec-d133-43cf-b8fe-956a8169cf59)
and [Decision 7/2019 arts. 2–4](https://almeezan.qa/legislations/66ff7dfb-2ed4-4454-9861-69f2d1508104).
The new ITL art. 24(10)–(12) offences took effect on 1 January 2025 and are not
confined to Pillar Two. A TP adjustment requires considering the actual
information, filing and payment offences, not just additional ordinary tax.

CbCR delay runs from the day after the deadline until submission: Decision
7/2019 art. 4. Apply the QAR 500,000 statutory ceiling under Decision 16/2019
art. 7 and ITL art. 24(8), not the ordinary late-return QAR 180,000 cap.
Do not assume different offences or their caps aggregate in a particular way
without examining the breach and assessment.

ITL art. 24(10) also places the specified QAR 30,000 penalty on the last managers
or persons in charge where records are not retained for five years after
dissolution. This does not shorten an otherwise applicable longer retention or
dispute obligation.

## Cross-border points

The foreign-related-entity condition applies to master/local files, not to the
basic arm's length obligation or declaration test. For PE dealings apply ER
art. 63. Review nonresident withholding separately from pricing: ITL art. 9(2)
and ER arts. 21–24. A supportable related-party charge can still attract
withholding. See [qa-cross-border-tax](qa-cross-border-tax.md).

An adjustment does not itself give the counterparty a foreign deduction or
corresponding adjustment. Inspect the applicable treaty and its dispute procedure
through the [GTA treaty directory](https://www.gta.gov.qa/en/agreements).
ER art. 64 contemplates bilateral advance pricing arrangements. Under the
[GTA 2026 bilateral APA guide, pp. 2–8](https://www.gta.gov.qa/assets/pdf/GTA_BAPAM_Annex_Guide_En_20260429.pdf),
notify both competent authorities before filing, then submit identical requests
simultaneously to both. Use English if there is no common language unless the
authorities agree otherwise. Qatar's acceptance target is 30 days from a complete
application; its resolution target is 30 months, with an aim of 24 as processes
improve. These are guidance targets, not statutory acceptance guarantees.
The guidance generally envisages at least five covered years, including two
prospective years, with unchanged facts. Agree the work plan after acceptance,
supply information to both authorities and continue filing covered-year returns
on the request's positions. Authorities conduct substantive negotiations; taxpayers
do not attend those negotiations. Renewal can be requested in the final year,
subject to the facts and authority decision.

The [GTA rollback guidance, sections 2–6](https://www.gta.gov.qa/assets/pdf/Guidance_on_Roll-Back_of_Bilateral_Advance_Pricing_Arrangements_20260329.pdf)
requires substantially unchanged earlier-year facts, an unexpired assessment
limitation period and GTA verification. That verification is not itself a tax
audit or an automatic adjustment. Separate audits and implementation adjustments
under an agreed APA remain possible. Keep rollback eligibility separate from
ordinary return correction and treaty dispute deadlines; no acceptance is promised.

Qatar's global minimum tax remains a separate computation:
[GTA minimum-tax framework](https://www.gta.gov.qa/en/global-minimum).

## Two worked examples that recompute

### 1. Underbilled services

A wholly foreign-owned taxable mainland company incurs QAR 1,000,000 of
otherwise deductible service costs. Its documented comparable analysis supports
a 5% cost markup; **5% is an assumed supported result, not a statutory rate**.
It bills its parent only QAR 1,000,000. Arm's length revenue is QAR 1,050,000;
the QAR 50,000 increase adds QAR 5,000 to ordinary income tax. Authority:
ER arts. 53–54 and 63; ITL art. 9.

```oa-check
name: Qatar services underbilling with evidenced assumed markup
inputs:
  costs: 1000000
  evidenced_markup: 0.05
  billed: 1000000
  tax_rate: 0.10
steps:
  arm_length_revenue: costs * (1 + evidenced_markup)
  adjustment: max(0, arm_length_revenue - billed)
  additional_tax: adjustment * tax_rate
expected:
  arm_length_revenue: 1050000
  adjustment: 50000
  additional_tax: 5000
```

### 2. Asset threshold met although turnover is low

A wholly foreign-owned company has QAR 9,000,000 turnover, exactly
QAR 50,000,000 assets and an overseas associated parent. Both the declaration
and master/local-file tests are met through assets, despite turnover below
QAR 10,000,000. Assume an otherwise deductible parent service charge of
QAR 1,200,000 but an evidenced arm's length maximum of QAR 1,050,000.
The QAR 150,000 excessive charge increases taxable income and tax by QAR 15,000.
This does not decide withholding or foreign corresponding relief.
Authority: Decision 4/2020 arts. 3 and 7; ER art. 63; ITL art. 9.

```oa-check
name: Qatar excessive parent charge and exact asset threshold
inputs:
  assets: 50000000
  declaration_threshold: 10000000
  files_threshold: 50000000
  charge: 1200000
  supported_charge: 1050000
  tax_rate: 0.10
steps:
  declaration_headroom: assets - declaration_threshold
  files_headroom: assets - files_threshold
  adjustment: max(0, charge - supported_charge)
  additional_tax: adjustment * tax_rate
expected:
  declaration_headroom: 40000000
  files_headroom: 0
  adjustment: 150000
  additional_tax: 15000
```

## Ask the client first

- Is the entity under mainland GTA rules, QFC rules or a special regime?
- Which parties are associated under the accounting standards, and where are
  they and any PEs resident?
- What are the Qatar entity/PE's annual turnover, total assets and year end?
- What transactions, agreements, functional analysis and comparables support
  the recorded charges, and do they reconcile to the accounts?
- Is the group multinational, what was its preceding-year consolidated revenue,
  and is this entity its ultimate or surrogate parent?
- What losses, exemptions, GTA notices, filing extensions and foreign tax disputes
  affect the adjustment or filing obligation?

## Sources

| Source | URL | Read on |
|---|---|---|
| OECD 2026 Qatar CbCR peer review, jurisdiction-confirmed current implementation and suspension, read with Qatar law/GTA circular | https://www.oecd.org/en/publications/country-by-country-reporting-compilation-of-2026-peer-review-reports_353cb719-en/full-report/qatar_b342d28e.html | 2026-10-24 |
| GTA bilateral APA guide, pp. 2–8 | https://www.gta.gov.qa/assets/pdf/GTA_BAPAM_Annex_Guide_En_20260429.pdf | 2026-10-24 |
| GTA rollback guidance, sections 2–6 | https://www.gta.gov.qa/assets/pdf/Guidance_on_Roll-Back_of_Bilateral_Advance_Pricing_Arrangements_20260329.pdf | 2026-10-24 |
| GTA consolidated Income Tax Law 24/2018, including Law 11/2022; ER 39/2019, including Decision 3/2023; arts. cited above | https://www.gta.gov.qa/assets/pdf/Income%20Tax%20Law%20EN%202024.pdf | 2026-10-24 |
| Current Arabic ITL, including amended art. 24 | https://almeezan.qa/legislations/d444f6ad-68b1-4244-af96-6bf9ee39e065 | 2026-10-24 |
| Current Arabic ER, including arts. 52–64 | https://almeezan.qa/legislations/afee272e-4654-41c7-9e76-2b42f13c9b35 | 2026-10-24 |
| Law 22/2024, arts. 3 and 5; additional general penalties effective 1 January 2025 | https://almeezan.qa/legislations/3643a42a-bdc0-4546-95d6-975557616a1b | 2026-10-24 |
| GTA President's Decision 4/2020, arts. 1–12 | https://www.gta.gov.qa/assets/pdf/Resolution%20of%20President%20of%20General%20Tax%20Authority%20No.%20%284%29%20of%202020.pdf | 2026-10-24 |
| GTA Decision 10/2022, amending Decision 4/2020 arts. 8 and 11 | https://almeezan.qa/legislations/7e4d34ec-d133-43cf-b8fe-956a8169cf59 | 2026-10-24 |
| Finance Decision 16/2019 on CbCR, arts. 1–10, current Arabic legal-register text | https://almeezan.qa/legislations/14db8fef-545b-4c66-b34e-938f3755d541 | 2026-10-24 |
| GTA Circular 10/2020, parent/non-parent CbCR notice treatment | https://www.gta.gov.qa/assets/pdf/Circular%20of%20the%20GTA%20President%20No.%20%2810%29%20of%202020.pdf | 2026-10-24 |
| GTA Decision 7/2019, CbCR notification/report penalties | https://almeezan.qa/legislations/66ff7dfb-2ed4-4454-9861-69f2d1508104 | 2026-10-24 |
| GTA declaration service; use Decision 4/2020 where its threshold summary differs | https://www.sharek.gov.qa/en/articles/general-tax-authority/declaration-of-transfer-pricing/679b1f296798e422f45ac255 | 2026-10-24 |
| GTA information exchange and Tabadol routing | https://www.gta.gov.qa/en/agreements-topics/automatic-info-exchange | 2026-10-24 |
| GTA treaty directory | https://www.gta.gov.qa/en/agreements | 2026-10-24 |
| GTA global minimum-tax framework, separate regime | https://www.gta.gov.qa/en/global-minimum | 2026-10-24 |

Not yet confirmed: none within ordinary mainland pricing, declaration,
master/local files and current mandatory CbCR scope. A specific voluntary
surrogate-parent arrangement and treaty dispute case require their own
eligibility, exchange and procedural analysis. QFC and Pillar Two are separate
special regimes.

General reference only. This source-cited draft is not a filing or a professional
attestation. A qualified Qatar tax professional must review the taxpayer's facts,
supporting documents and applicable law before filing or taking a tax position.

> Contributed by Michael Cutajar.