Qatar: Amendment of certain provisions of Income Tax Law for 2018

Among other important changes, Qatar introduced a global minimum tax, as well as numerous exceptions to its source-based taxation system

Amendment of certain provisions of Income Tax Law for 2018

The State of Qatar on 2 February 2023, issued the Law No. 11 of the year 2022 for the amendment of certain provisions of the Qatar Income Tax Law No. 24 of the year 2018.

Among other important changes, the State of Qatar introduced a global minimum tax, as well as numerous exceptions to its source-based taxation system to prevent double non-taxation.

New provisions introduced

  • Global minimum tax
  • Extended scope of income subject to tax
  • Relief for foreign taxes
  • Income attributable to a permanent establishment (PE) outside the State
  • Tax-exempt income

Major changes to pre-existing provisions

  • Tax residency criteria for natural and legal persons
  • Definition of PE
  • Full compliance requirements applicable to private associations and foundations, private charitable organizations, and private foundations of public interest

Other important changes

  • Economic substance regulations
  • Ultimate beneficial ownership details
  • New definitions introduced
  • Provisions under the Tax Law of 2022 relevant to transfer pricing

Effective date

The Tax Law of 2022 states that all concerned/relevant parties must implement the law but does not mention an effective date. 

KPMG observation

The absence of an explicit effective date could imply that the Tax Law of 2022 is applicable with immediate effect (i.e., from the date of its publication in the official gazette). If this is the case, clarification will be needed whether the changes will affect the tax filings of the financial year ending in 2022, which are due in 2023, or the tax filings of the financial years ending 2023.

Read a February 2023 report [PDF 821 KB] prepared by the KPMG member firm in Qatar

 

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