Qatar: local rules

Qatar's transfer pricing rules sit in Chapter II of Section Seven of the Executive Regulations of the Income Tax Law (arts. 52 to 64), issued by Cabinet Decision 39 of 2019 under Income Tax Law No. 24 of 2018 and amended by Cabinet Decision 3 of 2023. The Law itself has no arm's length article. The arm's length principle is art. 53 of the Regulations, defined as pricing between two independent entities. Related ('linked') entities are those under international accounting standards (art. 52). Every linked entity must test its prices by the time it files the return (art. 53), do a functional analysis (art. 54), refresh comparable financial data every year and redo the database search every 3 years if the business is unchanged (art. 55), and show the GTA on request that its deals are arm's length (art. 59). The GTA may add profit moved to a related entity through non-arm's length prices to taxable income (art. 63), and documentation does not stop an adjustment (art. 61). GTA President's Resolution No. 4 of 2020 sets the forms and thresholds.

Three items. First, a Transfer Pricing Declaration filed with the return, on the same date, by every resident entity or permanent establishment with turnover or total assets of QAR 10m or more; it lists related-party deals above QAR 200,000 (Resolution 4 of 2020, arts. 3 to 5). Second and third, a master file and a local file for entities with turnover or total assets of QAR 50m or more that have a group entity outside Qatar (art. 7), applying to years starting on or after 1 January 2020. The Resolution says 30 June of the following year (art. 8), but GTA Decision 10 of 2022, as reported by Deloitte, moved this to 60 days after the return due date (29 June for a 31 December year end). The decision text itself was not found. The GTA can ask for more information within 30 days of a request (Regulations art. 56). Records must be kept (art. 62).

Neither the Regulations nor Resolution 4 of 2020 list named methods. The Regulations ask for a functional analysis, comparables from financial databases and a tested party where relevant, and the local file must give 'the most appropriate transfer pricing method' with reasons, the tested party, assumptions, a comparables search and comparability adjustments (Resolution art. 10). The master and local files follow the OECD format unless the GTA adopts its own forms (Regulations art. 57). I found no official statement of preferred methods or an accepted range. The GTA transfer pricing FAQs, known only through EY's summary, were not read. A bilateral APA is foreseen (art. 64) but no APA rules were found.

There is no transfer pricing penalty in the Law. The general penalties apply (Law art. 24, as amended by Law 11 of 2022): QAR 500 per day for a late return, capped at QAR 180,000; 2% of the unpaid tax for each month or part month of late payment, capped at the tax due; QAR 20,000 for breaking registration or notice rules; QAR 30,000 for not filing audited accounts or keeping books; and up to QAR 500,000 for breaking the CbC and exchange of information decisions made under art. 34. Deloitte reports that a late master file or local file draws the QAR 500 per day charge. The President can waive penalties up to QAR 500,000 (art. 25), and the GTA ran a 100% penalty exemption initiative in 2025. Adjusted profit is taxed and is not a penalty in itself. Tax avoidance can lead to loss of the tax benefit (Regulations art. 50).

Qatar enacted Pillar Two through Law No. 22 of 2024, which added Chapter VII Bis to Income Tax Law 24 of 2018, and Council of Ministers Resolution No. 2 of 2026, published in the Official Gazette on 12 February 2026. It applies to fiscal years starting on or after 1 January 2025 and brings in a domestic minimum top-up tax (DMTT, also called QDMTT) and an income inclusion rule (IIR). No undertaxed profits rule was found. The scope test is EUR 750m of revenue in two of the four preceding years. A Designated Local Entity must register on the Dhareeba portal: for fiscal years starting in 2025 within 3 months of the GTA opening the service on 2 August 2026 (so by 2 November 2026), and after that within 6 months of each fiscal year end. The DMTT return, IIR return, GloBE information return and payment are due 15 months after the fiscal year end. The law gives 18 months only for the group's first transition year (its first year in scope anywhere), so groups already covered by another country's rules in 2024 likely get 15 months for fiscal year 2025, even though the GTA guide says 18 months for fiscal year 2025 'for most groups'. The tool shows the earlier 15 month date. Penalty relief can apply to fiscal years starting on or before 31 December 2027 and not ending after 30 June 2029 if the group shows it took reasonable steps to comply.

The CbC report is required of a Qatar-resident ultimate parent of a group with consolidated revenue of QAR 3bn or more in the prior year (Minister of Finance Decision 16 of 2019, art. 1 and art. 2). A Qatar-resident listed entity that is not the parent also files if the parent does not file or exchange is not working (art. 2(2)). The report is due 12 months after the group's fiscal year end (art. 5). The Qatar parent must tell the GTA it is the parent by the last day of the reported fiscal year (art. 3(1)); the GTA has also said other group entities need not notify (Circular 10 of 2020). Filing runs through the GTA's Tabadol portal according to Deloitte and press reports. The return is due within 4 months of the tax year end (Regulations art. 29) and the tax is paid with it (Law art. 20). The GTA may extend by up to 4 months on a request made at least 60 days before the due date (art. 30), and has also announced blanket extensions for recent years, usually excluding petroleum and petrochemical companies. The weekend is Friday and Saturday. No rule was found that moves a deadline falling on a weekend or holiday, so none is moved. Eid al-Fitr and Eid al-Adha follow the Hijri calendar and change each year.