|Corporate Income Tax Rate (%)||10|
|Capital Gains Tax Rate (%)||0 / 10|
|Branch Tax Rate (%)||10|
|Withholding Tax (%)||5 / 7|
|Net Operating Losses (Years)|
Taxes on corporate income and gains
Corporate income tax. Foreign companies, including partnerships and joint ventures, carrying on business activities in Qatar are subject to tax. Tax is imposed on a foreign entity operating in Qatar, regardless of whether it operates through a branch, a joint venture with a locally registered company or through a wholly owned subsidiary. However, Qatar tax resident companies wholly owned by Qataris and citizens of the other Gulf Cooperation Council (GCC) countries (Bahrain, Kuwait, Oman, Saudi Arabia and United Arab Emirates) are exempt from tax. Qatar tax resident companies that are not wholly owned by Qataris and other GCC citizens are taxable up to the level of profits ultimately attributable to the non-GCC national shareholders and to GCC national shareholders who are not tax residents in Qatar. Other GCC nationals are treated in the same manner as Qatari citizens for Qatar tax purposes.
Tax resident companies and permanent establishments (PEs) that are wholly owned by Qatari and other GCC nationals and that are exempt from corporate income tax must submit tax returns and audited financial statements to the Public Revenues and Taxes Department (PRTD) if their capital is QAR2 million or more or if their annual revenue is QAR10 million or more.
A company is considered to be a Qatar tax resident if it meets any of the following conditions:
- It is incorporated under the laws of Qatar.
- Its head office is located in Qatar.
- Its place of effective management is located in Qatar.
A PE is a fixed place of business through which the business of a taxpayer is wholly or partly carried on, including, among others, a branch, office, factory, workshop, mine, oil or gas well, quarry, building site, assembly project, or place of exploration, extraction or exploitation of natural resources. A PE also includes an activity carried on by the taxpayer through a person acting on behalf of the taxpayer or in its interest, other than an independent agent.
Rates of corporate income tax. Income is subject to tax at a standard rate of 10% of profits, as adjusted for tax purposes.
Petroleum companies engaged in oil operations are taxed at the rates specified in their agreements, provided that the tax rate is not less than 35% on their taxable income. Taxable income is determined in accordance with the provisions of the underlying production-sharing contract or development and fiscal agreement. Petroleum operations are defined by law as the exploration for petroleum, improving oil fields, drilling, well repair and completion, the production, processing and refining of petroleum, and the storage, transport loading and shipping of crude oil and natural gas. Oilfield service companies contracting with petroleum companies are subject to the standard 10% tax rate.
Foreign international shipping and aviation companies are exempt from tax in Qatar if Qatari shipping and aviation companies enjoy similar reciprocal treatment in the respective foreign countries.
Not-for-profit entities that are registered in Qatar or in another country are not covered by the provisions of the Qatar Income Tax Law and are accordingly exempt from tax. However, they must withhold tax if applicable.
The income of businesses registered and operating in the Qatar Financial Centre (QFC) is subject to a standard rate of tax of 10%. Regulated and non-regulated activities may be carried on from the QFC. Regulated activities include the following:
- International banking
- Insurance and reinsurance
- Fund management
- Brokerage and dealer operations
- Treasury management
- Funds administration and pension funds
- Financial advice and back-office operations
Non-regulated activities include the following:
- Professional and business services (including, but not limited to audit, legal, consultancy, tax advisory, media and public relations, project management, architecture and engineering)
- Holding company and headquarter hosting
- Special-purpose company
- Single-family office
- Ship brokering and agency services
- Trust and trust services
Companies engaged in captive insurance or reinsurance business and companies of which at least 90% of the ordinary capital, profit and asset entitlement are beneficially, directly or indirectly owned by Qatari nationals and are licensed to provide non-regulated activities may elect a 0% concessionary tax rate to apply to their chargeable profits.
Law No. 17 of 2014 provides a tax exemption for non-Qatari investors holding shares of companies or units in investment funds listed on the Qatar Stock Exchange. This exemption also extends to profits realized on the sale, transfer or exchange of listed shares or investment fund units.
Tax incentives. Tax exemptions may be granted for periods of three to six years for certain companies, regardless of the nationality of the owners. A committee evaluates applications for tax exemptions. It considers factors such as the following in reviewing the applications:
- Whether the company provides social or economic benefits to Qatar
- Whether the company falls within the planned development and economic objectives of the government and has the approval of the appropriate government department
- The extent to which the company contributes to the national economy
- Whether the company uses modern technology
- Whether the company creates employment opportunities for citizens
The income of businesses operating at the Qatar Science and Technology Park (QSTP) is exempt from tax. However, such businesses must file annual tax returns, together with audited financial statements, with the PRTD. QSTP-registered entities must also withhold tax if applicable.
Activities that may be carried out at the QSTP include the following:
- Research and development of new products
- Technology development and development of new processes
- Low-volume, high-value-added specialist manufacturing
- Technology-related consulting services, technology training and promotion of academic developments in the technology fields
- Incubating new businesses with advanced learning
To support financing and investment activities carried on by QFC entities, the QFC tax regulations provide for the establishment of tax-exempt vehicles. A QFC entity that is one of the following exempt vehicles may elect for special tax-exempt status:
- Registered Fund (QFC Scheme or a Private Placement Scheme)
- Special Investment Fund (permitted activities are private equity investments, venture capital investments, investments in property and investments on behalf of a single family)
- Special Funding Company (includes holding company and special-purpose company)
- Alternative Risk Vehicle
In addition, a newly registered and incorporated QFC company may be able to claim reimbursement in the form of a tax credit with respect to tax losses incurred in the first two accounting periods, subject to meeting all criteria. If a QFC company receives a reimbursement of tax losses, it is automatically precluded for the following three accounting periods from electing special exemption status or the concessionary 0% tax rate.
Capital gains. Capital gains are aggregated with other income and are subject to tax at the regular corporate income tax rate. The sale by nonresidents of shares in Qatar tax resident companies is taxable at a rate of 10%. However, the sale of shares in listed companies is exempt from tax.
Administration. Within 30 days after beginning a taxable activity in Qatar or registering with the Ministry of Business and Trade, a taxpayer must register with the PRTD and obtain a tax card.
The tax year runs from 1 January to 31 December, and a taxpayer must use this accounting period unless approval is obtained for a different year-end. Approval to use an alternative accounting period is granted in exceptional cases only.
In general, all companies, including tax-exempt companies (see Corporate income tax), must file tax declarations within four months after the end of the accounting period. The due date may be extended at the discretion of the PRTD, but the length of the extension may not exceed four months.
Audited financial statements must be submitted together with the tax declaration if any of the following circumstances exist:
- The capital of the taxpayer exceeds QAR100,000.
- The taxpayer’s total taxable income exceeds QAR100,000.
- The head office of the taxpayer is located outside Qatar.
The tax declaration must be certified by an accountant in practice in Qatar who is registered with the Ministry of Economy and Finance. If this requirement is not satisfied, the PRTD rejects the tax declaration. The tax declaration and supporting audited financial statements must be denominated in Qatari riyals.
Tax is payable on the due date for filing the tax declaration. The due date for payment of taxes may be extended if the filing date is extended and if the taxpayer provides reasons acceptable to the PRTD. Alternatively, the PRTD may allow taxes to be paid in installments during the extension period. Tax is payable in Qatari riyals.
Penalties for late filing are levied at a rate of QAR100 per day, subject to a maximum of QAR36,000. The penalty for late payment equals 1.5% of the tax due for each month or part of a month for which the payment is late, up to the amount of the tax due.
The PRTD may issue tax assessments based on a presumptive basis or reassess by applying market prices to certain related-party transactions in certain circumstances. The tax law provides for a structured appeals process with respect to such tax assessments. Correspondence for all appeals must be in Arabic. The appeals procedure consists of the following three stages:
- Correspondence and negotiations with the PRTD
- Formal appeal to an Appeal Committee
- The commencement of a case in the judicial courts
The PRTD may inspect a taxpayer’s books and records, which should be maintained in Qatar. The books and records are not required to be maintained in Arabic. The accounting books and records must be maintained for 10 years following the year to which the books, registers and documents are related.
The PRTD has introduced a new tax administration system through which correspondence with the tax authority primarily flows. This includes the filing of tax registration forms, tax return submissions and communications from the PRTD to the taxpayer with respect to inquiries, assessments and appeals.
For QFC entities, including tax-exempt entities, the annual income tax declaration must be submitted and the corresponding tax due must be paid within six months after the end of the accounting period.
Financial sanctions for the late submission of the annual tax declaration are levied based on when the delayed filing is submitted. In addition, the delay payment charge on unpaid tax, which is currently 5% per year, is imposed.
Withholding taxes. Qatar Tax Law No. 21 of 2009, which is effective from 1 January 2010, introduced withholding taxes on payments to nonresident entities for activities not connected with a PE (essentially, those without a Commercial Registration and Tax Card issued by the PRTD), and to entities registered in the Commercial Register with the registration linked to a specific project for a period of less than one year. The following are the payments subject to withholding tax and the applicable rates:
- Royalties and technical fees: 5%
- Interest payments (subject to specified exceptions), directors’ fees, attendance fees, brokerage, commissions and other payments with respect to contracts for services conducted wholly or partially in Qatar: 7%
Companies or PEs in Qatar that make the above payments must deduct tax at source and remit it to the PRTD by the 15th day of the month following the month in which the payment is made.
Dividends. Dividends paid by a Qatar tax resident company are not subject to withholding tax. Income distributed from profits that have already been subject to Qatar taxation are not subject to further taxation in the hands of the recipient. Dividends paid by an entity that has a tax exemption are exempt from tax.
Foreign tax relief. A deduction is allowed for income taxes incurred by the taxpayer abroad if the revenues related to the foreign taxes are taxable in Qatar, subject to other deductibility requirements. In addition, foreign tax relief is available under the tax treaties with the countries listed in Section E.
Determination of trading income
General. The following are some of the items that are included in taxable income:
- Interest and returns realized outside Qatar from amounts generated by taxable activity carried on in Qatar
- Revenues earned from an activity performed in Qatar including trading, contracting and the provision of services
- Revenues earned from the partial or total performance of a contract in Qatar
- Service fee income received by head offices, branches or related companies
- Certain dividend income and capital gains on real estate located in Qatar
- Interest on loans obtained in Qatar
Normal business expenses are allowable and must be determined under the accrual method of accounting. Branches are limited in the deduction of head office expenses (see Head office overhead). Self-employed individuals engaged in a professional activity may choose to deduct a notional expense equal to 30% of their total income instead of all of the expenses and costs that are allowed to be deducted. Expenses for entertainment, hospitality, meals, holidays, club subscriptions and client gifts are subject to restrictions. Guidance contained in supporting executive regulations specifies that these expenses are subject to an allowable ceiling of 2% of net income, up to a maximum of QAR200,000.
Inventories. Inventories must be valued using international accounting standards.
Provisions. General provisions, such as bad debts and stock obsolescence, are generally not allowed. Specific bad debts that are written off are deductible to the extent that they satisfy conditions set by the PRTD. Deductions by banks for loan-loss provisions are the subject of periodic instructions from the Qatar Central Bank and, in general, provisions are allowable up to a ceiling of 10% of net profits.
Head office overhead. In general, charges of a general or administrative na ture imposed by a head office on its Qatar branch are allowed as de ductions, provided that they do not exceed 3% of turnover less subcontract costs. However, for banks, the limit is 1%. If a project derives income from both Qatari and foreign sources, the limit is 3% of the total revenues of the project, less subcontract costs, revenues from the supply of machinery and equipment overseas, revenues derived from services performed overseas, value of paid reinsurance premiums and other income not related to activities in Qatar.
Tax depreciation. Under the executive regulations relating to the Qatar Income Tax Law, assets must be classified into two groups for tax depreciation purposes. The first group is for high-value assets and consists primarily of buildings, ships, airplanes, drilling instruments and intangible assets. These assets should be depreciated on a straight-line basis using the following annual depreciation rates:
|Buildings and constructions, including
roads, bridges, pipelines, storage tanks
and port ducts inside the establishment,
excluding ready-made light constructions
|Ships and boats||10|
|Airplanes and helicopters||20|
|Trademarks, patents and similar items||Amortized over the
expected life of the asset, with a maximum annual amortization allowance of 15%
For the second group, which relates to low-value assets, tax depreciation is calculated using the reducing-balance method. The following are the annual depreciation rates for these assets.
|First||Computer hardware and software
and annexes thereof
|Second||Machinery, plant, equipment,
electrical devices and means of
transportation of goods and
persons, including cars, vehicles,
trucks and cranes
|Third||Office furniture, fixtures and
fittings and other assets
The above depreciation rates must be applied to the written-down tax value of the assets, increased by the cost of current-year additions and decreased by the sales proceeds from current-year disposals. Under the Qatar Income Tax Law, the gain or loss resulting from disposal of low-value fixed assets is no longer considered for income tax purposes. Instead, the sales proceeds are deducted from the tax value of the assets as mentioned above.
Approval of the Minister of Finance is required for departure from the tax depreciation rates noted above. Departures from these rates are normally allowed only for new start-up projects if the project owner requests permission to adopt different depreciation rates based on the presentation of appropriate justifications to the Minister.
The Executive Regulations provide guidance on the deductibility of depreciation. Under the regulations, depreciation is allowed for tax purposes up to the amount contained in the financial statements.
Relief for losses. Losses may be carried forward for up to three years. Carryback of losses is not allowed.
Groups of companies. No tax regulations cover groups of companies.
Foreign-exchange controls. Qatar does not impose foreign-exchange controls. Equity capital, loan capital, interest, dividends, branch profits, royalties and management fees are freely remittable.
Transfer pricing and anti-avoidance legislation. The Qatar Income Tax Law contains anti-avoidance provisions. The PRTD may nullify or alter the tax consequences of any transaction that it has reasonable cause to believe was entered into to avoid or reduce a tax liability.
If a company carries out a transaction with a related party that was intended to reduce the company’s taxable income, the income arising from the transaction is deemed to be the income that would have arisen had the parties been dealing at arm’s length.
In determining the arm’s-length value, the PRTD requires use of the comparable uncontrolled price (CUP) method. Under this method, the price of the service or goods is deemed to be the price that would have been applied if the transaction had been between unrelated parties. If the information required to apply the CUP method is not available, an application to apply a different transfer-pricing method approved by the Organisation for Economic Cooperation and Development (OECD) must be submitted to the PRTD.
Under the QFC tax regime (see Section B), transfer pricing may be determined based on any of the accepted OECD transfer pricing methods.
A taxpayer’s presentation to the QFC Tax Department of a transfer-pricing study with pricing for related-party transactions, properly benchmarked against valid comparables, is a significant factor in deciding whether an inquiry into a return is necessary.
Thin-capitalization rules. The Qatar Income Tax Law does not provide for a safe harbor debt-to-equity ratio.
However, under the QFC tax regime, the following are safe harbor debt-to-equity ratios:
- 2:1 for non-financial institutions
- 4:1 for financial institutions
Although the above ratios are non-statutory and are non-binding on taxpayers and the QFC Tax Department, they are expected to be accepted as default thresholds by the QFC Tax Department. The safe-harbor guidance applies for accounting periods beginning on or after 1 January 2012.
Supply and installation contracts. Profits from “supply only” operations in Qatar are exempt from tax because the supplier trades “with” but not “in” Qatar. If a contract includes work elements that are performed partially outside Qatar and partially in Qatar, and if these activities are clearly separated in the contract, only the revenues from the activity performed in Qatar are taxable in Qatar.
Similarly, with respect to an engineering, procurement and construction contract for a project in Qatar, the obligation to perform construction work in Qatar may bring the revenues arising outside
Qatar into the Qatar tax net unless the contract clearly includes a split of revenue between work done in Qatar and work done outside Qatar.
Contract retention. All ministries, government departments, public and semipublic establishments and other payers must retain final contract payments or 3% of the contract value (after deducting the value of supplies and work done abroad), whichever is greater, due to foreign branches that are registered and that have a registration linked to a specific project with a duration of at least one year. The contract retention payable to the contractor or subcontractor must be retained until the contractor or subcontractor presents a tax clearance from the PRTD confirming that all tax liabilities have been settled.
Contract reporting. Ministries and other government bodies, public corporations and establishments, and companies are required to report to the PRTD on contracts concluded with nonresidents without a PE in Qatar, regardless of their value. In addition, contracts concluded with residents or with nonresidents that have a PE in Qatar must also be reported to the PRTD if the contract value amounts to QAR200,000 for service contracts, or to QAR500,000 for contracting, supply, and supply and service contracts. Copies of the contracts must also be submitted together with the statement, except for contracts concluded with nonresidents with no PE in Qatar that have a contract value not exceeding QAR100,000.
Tax treaty withholding tax rates
The table provided below is intended purely for orientation purposes. It does not reflect the various special provisions of individual treaties or the withholding tax regulations in domestic law. The following is a table of treaty withholding tax rates.
|Algeria||— (b)||—||— (c)||5|
|Austria||— (c)||— (c)||— (f)||5|
|Croatia||— (c)||—||— (c)||10|
|Cyprus||— (c)||—||— (c)||5|
|France||— (f)||—||— (f)||— (f)|
|Georgia||— (c)||—||— (c)||— (g)|
|Hong Kong SAR||—||—||—||5|
|Hungary||0/5 (bb)||0 (bb)||— (c)||5|
|Isle of Man||— (c)||— (c)||— (c)||5|
|Jersey||— (c)||— (c)||— (c)||5|
|Latvia||5 (gg)||0 (gg)||0/5 (gg)||5|
|Lebanon||— (j)||—||— (j)||— (j)|
|Luxembourg||5/10 (k)||0 (h)||— (c)||5|
|Macedonia||— (c)||—||— (c)||5|
|Malaysia||5/10 (l)||5 (l)||5||8|
|Malta||— (c)||—||— (c)||5|
|Mauritius||— (c)||—||— (c)||5|
|Monaco||— (c)||—||— (c)||5|
|Netherlands||10||0 (n)||— (c)||5|
|Norway||15||5 (h)||— (c)||5|
|Portugal||10||5 (dd)||10 (a)||10|
|Senegal||— (j)||—||— (j)||— (j)|
|Seychelles||— (c)||—||— (c)||5|
|Sudan||— (b)||—||— (c)||— (z)|
|Switzerland||10/15 (o)||5 (p)||— (c)||— (c)|
|Tunisia||0 (q)||0||— (r)||5|
|Turkey||15||10 (s)||10 (t)||10|
|United Kingdom||0 (u)||0||0 (v)||5|
|Vietnam||12.5||5 (w)||10||5/10 (x)|
|Yemen||— (c)||—||— (c)||— (y)|
|Non-treaty countries||0||0||7 (cc)||5 (cc)|
A Individuals and companies
B Qualifying companies
a) Some treaties provide for an exemption for certain types of interest, such as interest paid to public bodies and institutions. Such exemptions are not considered in this column.
b) Income may be taxed in the residence state at the rate provided under its domestic law.
c) Income is taxable only in the residence state at the rate provided under its domestic law.
d) The 5% rate applies if the beneficial owner has invested capital of more than USD100,000.
e) The 5% rate applies if the beneficial owner holds at least 25% of the capital of the company paying the dividends.
f) Dividends, interest and royalties are taxable only in the residence state at the rates provided under its domestic law if the recipient is the beneficial owner of the income.
g) Royalties are taxable only in the residence state at the rates provided under its domestic law if the recipient is the beneficial owner of the income.
h) This rate applies if the beneficial owner holds at least 10% of the capital of the company paying the dividends.
i) The 5% rate applies if the beneficial owner has owned directly or indirectly at least 25% of the capital of the company paying the dividends for a period of at least 12 months preceding the date on which the dividends are declared.
j) Dividends, interest and royalties are taxable in the residence state at the rates provided under its domestic law.
k) The 5% rate applies if the beneficial owner is an individual who holds directly at least 10% of the capital of the company paying the dividends and who has been a resident of the other contracting state for a period of 48 months immediately preceding the year in which the dividends are paid.
l) The 5% rate applies if the beneficial owner is an individual or a company that holds directly at least 10% the capital of the company paying the dividends. Otherwise, a 10% rate applies.
m) The 5% rate applies if the beneficial owner holds directly at least 10% of the capital of the company paying the dividends.
n) The 0% rate applies if the beneficial owner is a company that has its capital wholly or partly divided into shares and that holds directly at least 7.5% of the capital of the company paying the dividends.
o) The 10% rate applies if the individual holds at least 10% of the capital of the distributing company. Otherwise, the 15% rate applies.
p) The 5% rate applies if the beneficial owner is a company that holds directly at least 10% of the capital of the company paying the dividends.
q) The income is not taxable in either state.
r) The income may be taxed in the source state at the rate provided under its domestic law.
s) The 10% rate applies if the beneficial owner is a company that holds directly at least 25% of the capital of the company paying the dividends. Otherwise, the 15% rate applies.
t) The income is exempt from tax if it is beneficially owned by the government of the contracting state or a political subdivision or a local authority thereof or by the central bank of the other contacting state.
u) Dividends distributed by real estate investment trusts are subject to a 15% withholding tax, unless the beneficial owner is a pension scheme, in which case an exemption applies.
v) The treaty provides for several alternative conditions relating to the beneficial owner or the payer of the interest for the application of the 0% rate. This rate applies if one of these conditions is met. Otherwise, the domestic rate in the source state applies.
w) The 5% rate applies if the beneficial owner is a company that holds directly or indirectly at least 50% of the capital of the company paying the dividends or that has invested more than USD10 million or the equivalent in Qatari or Vietnamese currency in the capital of the company paying the dividends.
x) The 5% rate applies to royalties paid for the following:
- The use of, or the right to use, patents, designs or models, plans, or secret formulas or processes
- The use of, or the right to use, industrial, commercial or scientific equipment
- Information concerning industrial, commercial or scientific experience. The 10% rate applies in other cases.
y) The income is taxable only in the source state at the rate provided under its domestic law.
z) The income may be taxed in the source state at the rate provided for under its domestic law.
(aa) This rate applies if the beneficial owner is a company (other than a partnership) that holds at least 10% of the capital of the company paying the dividends.
(bb) The 0% rate applies if the beneficial owner of the dividends is a company resident in the other contracting state. The 5% rate applies to all other beneficial owners of dividends resident in the other contracting state.
(cc) See Section B.
(dd) This rate applies if the beneficial owner of the dividends holds at least 10% of the capital of the company paying the dividends or if the beneficial owner is the state of Portugal, a political or administrative subdivision or a local authority thereof, or the central bank of Portugal.
(ee) The 5% rate applies if the beneficial owner of the interest is a bank. A 10% rate applies in all other cases.
(ff) The 5% rate applies if the beneficial owner is a company (other than a partnership) that holds directly at least 20% of the capital of the company paying the dividends.
(gg) The rate is 0% if the beneficial owner is a company (other than a partnership). The rate is 5% of the gross amount of the dividends or interest in all other cases.
Qatar is in the process of ratifying treaties with Barbados, Bermuda, Bosnia and Herzegovina, Ethiopia, Fiji, Gambia, Kenya, Mauritania, the Philippines and San Marino.
Qatar is in the process of negotiating, signing and ratifying treaties with Albania, Belgium, Brunei Darussalam, Egypt, Eritrea, Estonia, Finland, Germany, Iceland, Japan, Kazakhstan, Libya, Lithuania, Montenegro, Peru, South Africa, Spain, Thailand, Turkmenistan, Ukraine, Uruguay and Uzbekistan.
Qatar is renegotiating its tax treaties with Morocco and Turkey.