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state regime administered by the General Tax Authority (GTA)
Qatar has two tax regimes,
the Qatar Financial Centre (QFC) regime administered by the QFC Tax Department. Unless specifically stated other wise, the information in this chapter relates to the state tax regime.
A. At a glance
Corporate Income
Gains
Tax Rate
B. Taxes on corporate income and gains
Corporate income tax. Qatar has two independent taxation frame works. State-registered entities are subject to the State Income Laws, while entities registered in the QFC are subject to QFC regulations.
The basis of taxation in Qatar is territorial. Persons carrying on business activities in Qatar are subject to tax on profits arising from sources in Qatar. Income from outside Qatar is generally not subject to tax.
Companies are exempt from tax to the extent that they are owned by Qatari shareholders who are tax resident in Qatar and to the extent of the profits that are attributable to citizens of the other Gulf Cooperation Council (GCC) countries (Bahrain, Kuwait, Oman, Saudi Arabia and the United Arab Emirates) who are tax resident in Qatar.
Rates of corporate income tax. The standard corporate tax rate is 10%.
Companies engaged in petrochemical industries and petroleum 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 de velopment and fiscal agreement. Petroleum operations are de fined by law as the exploration for petroleum, improving oil fields, drilling, well repair and completion, the production, pro cessing and refining of petroleum, and the storage, transport loading and shipping of crude oil and natural gas. Oilfield ser vice companies contracting with petroleum and petrochemical 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 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 rela tions, 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
Tax incentives. Taxpayers may seek approval for an exemption or preferential tax rate for projects based on criteria related to the nature of a project or its location. The Ministry of Finance may grant exemptions for up to five years. The Council of Ministers may approve exemptions for longer periods, or approve a preferential tax rate.
Taxpayers enjoying tax exemptions are required to submit their annual corporate tax return showing the amount of income that would have been taxable without the exemption, and the amount of tax exempted. Failure by a tax-exempt entity to file exemption documents together with the tax return results in a penalty of QAR10,000.
The income of businesses operating at the Qatar Science and Technology Park (QSTP) is exempt from tax. However, such busi nesses must file annual tax returns, together with audited finan cial statements, with the GTA. QSTP-registered entities must also withhold tax if applicable.
Activities that may be carried out at the QSTP include the follow ing:
• 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, subject to meeting certain conditions:
• Registered Fund (QFC Scheme or a Private Placement Scheme)
• Special Investment Fund (permitted activities are private equity investments, venture capital investments, investments in prop erty and investments on behalf of a single family)
• Special Funding Company (includes holding company and special-purpose company)
• Alternative Risk Vehicle
QFC firms whose shares are listed on the Qatar Stock Exchange may elect for special tax exemption, subject to meeting certain conditions.
QFC firms that are engaged in captive insurance or reinsurance business, and of which at least 90% of their ordinary capital, profit and asset entitlement is beneficially, directly or indirectly owned by Qatari nationals (and are licensed to engage in
unregulated activities), and investment managers meeting certain conditions may elect a 0% concessionary tax rate for their chargeable profits.
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 ex emption status or the concessionary 0% tax rate.
Law No. 24 of 2018 provides a tax exemption for non-Qatari in vestors holding shares of companies or units in investment funds listed on the Qatar Stock Exchange (non-QFC entities). This ex emption also extends to profits realized on the sale, transfer or exchange of listed shares or investment fund units.
Capital gains. Capital gains are aggregated with other income and are subject to tax at the regular corporate income tax rate. The sale by foreign nationals and nonresident GCC nationals of shares in Qatar tax resident companies is taxable at a rate of 10%. However, the sale of shares (and the share of profits) in listed companies is exempt from tax.
Gains resulting from the revaluation of assets that are used as inkind contributions to the capital of another resident stockholding company are exempt, provided that the shares of that company are not sold within five years.
Capital gains derived by a QFC taxpayer may be exempt from tax in the QFC if they are considered non-local source or meet the conditions of the QFC participation exemption.
Administration. A taxpayer must register with the GTA via the GTA tax administration portal, Dhareeba, and obtain a Tax Card and Tax Identification Number within 60 days after commencing a taxable activity in Qatar or register with the Ministry of Economy and Commerce. Failure to register for tax results in a penalty of QAR20,000.
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 account ing period is granted in exceptional cases only.
In general, all companies, including tax-exempt companies (see Tax incentives), must file corporate income tax declarations, denominated in Qatar riyals, within four months after the end of the accounting period. The due date may be extended at the dis cretion of the GTA, but the length of the extension may not ex ceed four months.
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 GTA. Alternatively, the GTA may allow taxes to be paid in install ments during the extension period. Tax is payable in Qatari riyals.
Penalties for late filing are levied at a rate of QAR500 per day, subject to a maximum of QAR180,000. The penalty for late
payment equals 2% 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 GTA 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 GTA
• Formal appeal to an Appeal Committee
• The commencement of a case in the judicial courts
The GTA 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.
Tax return submissions and communications from the GTA to the taxpayer with respect to inquiries, assessments and appeals are communicated via the Dhareeba online portal.
For QFC entities, including tax-exempt entities, the annual in come 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 QFC tax declaration are levied based on when the delayed filing is submit ted. In addition, the delay payment charge on unpaid tax, which is currently 5% per year, is imposed. An additional financial penalty up to the amount of assessed tax due may be levied by the QFC Tax Department.
Withholding taxes. Payments with respect to royalties, interest, commission, services conducted wholly or partially in Qatar made to nonresident entities for activities not connected with a permanent establishment (PE) in Qatar (essentially, those without a Tax Card issued by the GTA) are subject to 5% withholding tax. Services are deemed to be conducted in Qatar to the extent that they are used, consumed or exploited in Qatar, even if rendered wholly or partially outside Qatar.
Companies or PEs in Qatar that make the above payments must deduct tax at source and remit it to the GTA by the 15th day of the month following the month in which the payment is made. The penalty for a failure to deduct withholding tax equals 100% of the withholding tax amount. Penalties for late remittance to the GTA of the amount withheld are levied at a rate of 2% per month, up to a maximum of 100% of the withholding tax due.
There is currently no withholding tax regime in the QFC. QFC taxpayers are not required to withhold tax.
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.
Dividends paid to a QFC taxpayer are not subject to tax in the QFC.
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.
In the QFC, tax resident taxpayers may credit foreign taxes imposed on income that is also taxed in the QFC either through a double tax treaty or unilateral relief, or they may elect to treat such taxes as deductible expenses.
C. 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 gener ated 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 con tract 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, holi days, club subscriptions and client gifts are subject to restrictions. Guidance contained in supporting Executive Regulations speci fies that these expenses are subject to an allowable ceiling of 2% of net income, up to a maximum of QAR500,000.
Inventories. Inventories must be valued using international ac counting standards.
Provisions. General provisions, such as bad debts and stock obso lescence, are generally not allowed. Specific bad debts that are written off are deductible to the extent that they satisfy conditions set by the GTA. 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 adminis trative nature imposed by a head office on its Qatar branch are allowed as deductions, 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. No such restriction applies in the QFC.
Tax depreciation. Under the Executive Regulations relating to the Qatar Income Tax Law, assets should be depreciated on a straight-line basis using the following annual depreciation rates:
Asset Rate (%)
Buildings and facilities
Buildings and durable facilities 5
Prefabricated light buildings 10 Roads, bridges, railways, and electrified railways 5 Pipelines, tanks and platforms 5
Pipelines and refining equipment within the refinery and small tanks 10 Networks and channels 5 Transportation Cargo and passenger means of transportation, including cars, vehicles, tractors, trailers, cranes and motorcycles 20 Ships and boats 10
Airplanes and helicopters 20 Rail transport and electrical rail transport 10
Intangible assets
Pre-establishment expenses 50 Trademarks, patents and similar items 15
Capitalized research and development expenses 20
Machinery and equipment
Computer hardware, software and accessories 33 Machinery, equipment and electrical appliances 20 Industrial machinery and equipment 20 Machinery and public works and construction equipment 20
Drilling tools 15
Air conditioners 25
Passenger and cargo elevators and escalators 15
Furniture and office equipment 15 Gas fixture, transportation and distribution equipment 5 Electricity and water production, transmission and distribution equipment 5
Machinery, equipment and other fixtures 15 Hotels, hostels, resorts, restaurants and cafes
Cooking and washing machines 20
Glass utensils 50
Other utensils 25
Furniture, furnishings and décor works 25 Swimming pools and accessories thereof 15
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 startup 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 limit the deductibility of deprecia tion to the amount reflected in the financial statements.
In the QFC, tax depreciation should be in line with the deprecia tion in the financial accounts, subject to additional requirements of the QFC tax regulations.
Relief for losses. Losses may be carried forward for five years. The carryback of losses is not allowed.
In the QFC, losses may be carried forward indefinitely, and the carryback of losses is not allowed.
Groups of companies. No tax regulations cover groups of compa nies in the Qatar Income Tax Law.
In the QFC, companies that are members of the same group may apply for a group relief (offset of taxable profits and losses).
D. Other significant taxes
Qatar has signed and ratified the GCC Value-Added Tax (VAT) Framework Agreement, and it is anticipated that Qatar will intro duce VAT in 2022. Because the GCC operates as a single customs territory, the GCC VAT Framework Agreement follows many of the principles in the EU VAT system.
The standard rate of VAT in Qatar is expected to be 5%.
Qatar has also signed and ratified the GCC Common Excise Tax Agreement and has introduced excise tax on tobacco and tobacco derivatives, carbonated drinks, energy drinks, and specialpurpose goods as of 1 January 2019.
E. Miscellaneous matters
Qatar Free Zones. The Qatar Free Zone Authority (QFZA) was created in 2018 as an independent authority to regulate and develop the Qatar Free Zones (QFZs). The QFZs are situated in geographically strategic areas to provide investors with direct access to Qatar’s airports and seaports and connect them with global markets. Foreign investors may establish a wholly owned company or branch in these QFZs. In addition, entities licensed in the QFZs are entitled to a 20-year income tax exemption from the establishment of the QFZA and customs exemption on goods imported into them, renewable for similar or more periods.
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 GTA may nul lify 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.
Under Qatar’s tax regime, in determining the arm’s-length value, the GTA requires the 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 Co-operation and Development (OECD) must be submitted to the GTA. Under the QFC tax re gime, transfer pricing may be determined using the accepted OECD transfer-pricing methods, and there is no requirement to seek pre-approval to use any of these transfer-pricing methods.
A group Master File and Qatar Local File should be submitted via the GTA’s Dhareeba portal if one of the group’s entities is resident outside Qatar and if the local entity or permanent estab lishment’s annual revenue or total assets meets or exceeds the statutory threshold of QAR50 million in the reporting year.
In addition to the transfer-pricing documentation, there is an ad ditional transfer-pricing compliance requirement in Qatar. A transfer-pricing statement (together with the annual tax declaration) should be completed and submitted by the Qatar entity via the GTA’s Dhareeba portal if the local entity or permanent estab lishment’s annual revenue or total assets meets or exceeds the statutory threshold of QAR10 million in the reporting year.
There is currently no formal advance pricing agreement (APA) regime in Qatar. However, APA regulations are expected to be issued by the local tax authority soon.
Under the QFC tax regime, a taxpayer’s presentation to the QFC Tax Department of a Qatar local file or a local transfer-pricing documentation report (including functional analysis and bench marking study) is generally required in the event of a tax or transfer-pricing inquiry.
Country-by-Country Reporting. On 14 November 2017, Qatar joined the inclusive framework for the global implementation of the Base Erosion and Profit Shifting (BEPS) Project. As a BEPS Associate, Qatar is committed to implementing four minimum standards under the BEPS Project, one of which is Action 13 on transfer-pricing documentation.
On 19 December 2017, Qatar signed the Multilateral Competent Authority Agreement on the exchange of Country-by-Country (CbC) Reports. The signing of this agreement enables Qatar to efficiently establish a wide network of exchange relationships for the automatic exchange of CbC Reports. As of the end of 2020, Qatar has activated its (non-reciprocal) exchange relationship with approximately 60 countries.
As part of the proposed implementation of Action 13 of the BEPS Project, Qatar published Ministerial Decision No. 16 of 2019, which outlines CbC Reporting requirements in Qatar that are applicable for tax years beginning on or after 1 January 2018. The CbC Reporting rules are aligned with the model legislation set out in the OECD’s BEPS Action 13 Final Report on CbC Reporting. These requirements also apply to entities that are registered in the QFC.
An ultimate parent entity that is tax resident in Qatar is required to submit a CbC Reporting notification and file a CbC Report in
Qatar if it is a member of a multinational enterprise group that had consolidated group revenue of at least QAR3 billion in the preceding fiscal year. The annual CbC Reporting notification must be submitted by the end of the reporting tax year. CbC Reports should be filed with Qatar’s Tabadol Portal within 12 months after the end of the reporting tax year.
Noncompliance with CbC Reporting notification is subject to a penalty of QAR100 per day for delay of filing or submission of false or incorrect information in the notification. Failure to com ply with the CbC Reporting requirements is subject to a penalty of QAR500 per day for delay of filing or submission of false or incorrect information in the report.
Currently, Qatar’s CbC Reporting requirements do not apply to entities of a foreign company that operates in Qatar in the form of a subsidiary or a PE.
Thin-capitalization rules. The Executive Regulations indicate that for tax residents, the amount of an intercompany loan should not exceed the debt-equity ratio of 3:1 for interest deductibility pur poses.
Interest paid by a PE to its head office or a related entity is not deductible.
However, under the QFC tax regime, the following are safe har bor debt-to-equity ratios:
• 2:1 for nonfinancial 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 begin ning on or after 1 January 2012. A higher debt-to-equity ratio may be accepted by the QFC Tax Department.
Supply and installation contracts. Profits from “supply only” op erations 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.
Contract retention. All ministries, government departments, pub lic and semipublic establishments and other payers must retain the final contract payment or 3% of the contract value (after de ducting the value of supplies and work done abroad), whichever is greater, due to foreign branches that have a commercial regis tration linked to a specific project with a duration of at least one year. The contract retention payable to the contractor or subcon tractor must be retained until the contractor or subcontractor presents a tax clearance from the GTA confirming that all tax liabilities have been settled.
Contract retention does not apply to QFC taxpayers.
Contract reporting. Ministries and other government bodies, pub lic corporations and establishments, and companies are required to report to the GTA on contracts concluded with nonresidents
without a PE in Qatar, regardless of their value. In addition, con tracts concluded with residents or with nonresidents that have a PE in Qatar must also be reported to the GTA 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 state ment, except for contracts concluded with nonresidents with no PE in Qatar that have a contract value not exceeding QAR100,000. A failure to comply results in a penalty of QAR10,000 per contract.
Contract reporting does not apply to QFC taxpayers.
Multilateral Instrument. On 4 December 2018, Qatar signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (Multilateral Instrument, or MLI). The MLI seeks to facilitate the efficient updating of existing tax treaties to incorporate treaty-related measures recommended by the OECD to counter base erosion and profit shifting, without the need for jurisdictions to bilaterally renegotiate each tax treaty.
Qatar deposited its instrument of ratification for the MLI with the OECD on 23 December 2019. The MLI entered into force on 1 April 2020.
At the point of the MLI ratification, Qatar indicated that it wants to amend its double tax treaties with 76 countries by using the MLI.
Common Reporting Standard. Qatar is one of the jurisdictions that has committed to implement the Common Reporting Standard (CRS). The CRS is a standard developed by the OECD relating to automatic exchange of financial account information and re quires jurisdictions to obtain information from their financial institutions and automatically exchange that information with other jurisdictions on an annual basis. On 10 November 2017, Qatar signed the CRS Multilateral Competent Authority Agreement (CRS MCAA). The signing of the CRS MCAA en ables Qatar to efficiently establish a wide network of exchange relationships for the automatic exchange of information under CRS.
The effective date for the CRS in Qatar was 1 July 2017. Reporting Financial Institutions (such as banks, funds, brokers, custodians and insurance companies offering cash value or annu ity products) must have processes and procedures in place to meet their compliance requirements.
Individuals and entities that are not Reporting Financial Institutions should be prepared to provide relevant documenta tion to Reporting Financial Institutions to support their tax resi dency status.
The annual reporting deadline is 31 July following the year to which the data relates (subject to change by the GTA).
Economic substance rules. On 17 October 2021, Qatar introduced economic substance rules via the Resolution of the Minister of Finance No. 20 of 2021 for companies that are engaged in relevant activities and intellectual property activities and that benefit
from a Preferential Tax System (Qualified Entities). The rules will enter into force on 31 December 2023.
The Preferential Tax System is defined as any system that pro vides a preferential tax benefit that is not available under the general tax system of the state, regardless of its form, nature of benefit or its amount. Therefore, entities established under the QSTP, the Qatar Free Zone and the QFC (together referred to as Licensed Authorities) that are benefitting from the Preferential Tax System would be covered under these regulations.
The following are the relevant activities under the regulations:
Head office
Center for distribution and other services
Finance acquisition of assets and leasing of assets
Treasury funds management
Banking
Insurance
Shipping
Holding companies
Technical consulting
Technical training
To continue benefiting from the Preferential Tax System, Qualified Entities should meet certain requirements, such as conducting of a core income-generating activity in Qatar, having adequate number of full-time employees in Qatar, incurring an adequate amount of operational expenses to carry out activities and meeting the other requirements set by the Licensed Authorities.
The Resolution does not provide for reporting compliance re quirements but requires Qualified Entities to maintain certain information to be provided to the Licensed Authorities and com petent authorities on request.
F. Tax treaty withholding tax rates
The table provided below is intended purely for orientation pur poses. It does not reflect the various special provisions of indi vidual treaties or the withholding tax regulations in domestic law. The following is a table of treaty withholding tax rates.
Dividends
Albania
(ss)
Brunei Darussalam
Mainland
B Interest (a) Royalties
5
5
10
10
5
Dividends
A B Interest (a) Royalties % % % %
Cyprus (c) (c) 5
Ecuador 5/10 (p) 0/5 (p) 10 (ll) 10
France (f) (f) (f)
Georgia (c) (c) (g)
Greece 5 5 5 5
Guernsey 5
Hong Kong SAR 5
Hungary 0/5 (bb) 0 (bb) (c) 5
India 10 5 (h) 10 10
Indonesia 10 10 10 5
Iran 7.5 5 (ff) 10 5
Ireland 5
Isle of Man (c) (c) (c) 5
Italy 15 5 (i) 5 5
Japan 10 5 (hh) 0/10 (ii) 5
Jersey (c) (c) (c) 5
Jordan 10 10 5 10 Kazakhstan 5/10 (m) 5 (m) 10 (ll) 10
Kenya 10 0/5 (jj) 10 10
Korea (South) 10 10 10 5
Kyrgyzstan 5
Latvia 0/5 (gg) 0 (gg) 0/5 (gg) 5 Lebanon (j) (j) (j)
Luxembourg 5/10 (k) 0 (h) (c) 5 Malaysia 5/10 (l) 5 (l) 5 8 Malta (c) (c) 5
Mauritius (c) (c) 5
Mexico 5/10 (ee) 10 Monaco (c) (c) 5 Morocco 10 5 (m) 10 10
Nepal 10 10 10 15
Netherlands 10 0 (n) (c) 5
North Macedonia (c) (c) 5
Norway 15 5 (aa) (c) 5 Pakistan 10 5 (h) 10 10
Panama 6 0/6 (mm) 6 6
Philippines 15 10 (aa) 10 15
Poland 5 5 5 5
Portugal 10 5 (dd) 10 (a) 10 Romania 3 3 3 5
Russian Federation 5 5 5 (c)
San Marino (c) (c) (c) 5
Senegal (j) (j) (j)
Serbia 10 5 (e) 10 10
Seychelles (c) (c) 5 Singapore (c) 5 10 Slovenia 5 5 5 5
South Africa 10 0/5 (jj) 0/10 (kk) 5
Spain 5 0 (nn) 0 0
Sri Lanka 10 10 10 10
Sudan (b) (c) (z)
Switzerland 10/15 (o) 0/5 (rr) (c) (c)
Syria 5 5 10 18
Dividends
Tunisia
(s)
Interest
(t)
Ukraine 10 0/5 (oo) 5/10 (pp) 5/10 (qq)
United Kingdom
(u) 0/15 (u)
(h)
(w)
(v)
5/10 (x)
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 con sidered 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 voting stock of the company paying the dividends. The 0% rate applies to dividends distributed to certain state-owned entities.
(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) This rate applies if the beneficial owner is the government or a public institu tion that is wholly owned by the government or its political subdivisions or local authorities, of the other contracting state or a company (other than a partnership) that holds directly at least 20% of the capital of the company paying the dividends. Otherwise, the 10% 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 benefi cial 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 equip ment
• 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 partner ship) that holds at least 10% of the capital of the company paying the divi dends.
(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 ben eficial 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 part nership) 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 partner ship). The rate is 5% of the gross amount of the dividends or interest in all other cases.
(hh) The 5% rate applies if, for the six-month period ending on the date on which entitlement to the dividends is determined, the beneficial owner of the divi dends owned at least 10% of the voting power or the total issued shares of the company paying the dividends, and if the company paying the dividends is not allowed a tax deduction for the dividends.
(ii) The 0% rate applies if the interest is derived from government debt or if the beneficial owner is one of the following:
• A government entity
• A bank
• An insurance company
• A securities dealer
• A pension fund (conditions apply)
• Any other enterprise, provided that in the three tax years preceding the tax year in which the interest is paid, the enterprise derives more than 50% of its liabilities from the issuance of bonds in the financial markets or from taking deposits for interest and more than 50% of the assets of the enterprise consist of debt-claims against persons not associated with the enterprise
(jj) The 5% rate applies if the beneficial owner holds at least 10% of the capital of the company paying the dividends. The 0% rate applies to dividends paid to the other contracting state or a local authority, political subdivision or statutory body thereof.
(kk) The 0% rate applies if the interest arises with respect to a government debt or debt listed on a recognized stock exchange.
(ll) Exemptions apply to certain specified state-owned entities.
(mm) The 0% rate applies to dividends beneficially owned by a contracting state, a political subdivision, a local authority, an investment authority, the central bank or a pension fund thereof or any other entity or institution that is rec ognized, by mutual agreement, as an integral part of the state and is exempt from tax in the source state.
(nn) The exemption applies if the recipient company holds directly at least the following percentage of the capital of the company paying the dividends:
• 1% if the dividends are paid by a company, the shares of which are sub stantially and regularly traded on a stock exchange
• 5% if the beneficial owner of the dividends is a public body
• 10% in other cases
(oo) The 0% rate applies to dividends beneficially owned by a contracting state, a political subdivision, a local authority, an investment authority, the central bank or a pension fund thereof or any other institution or fund that is recog nized, by mutual agreement, as an integral part of the state, political subdivi sion or local authority. The 5% rate applies if the beneficial owner is a company (other than a partnership) that holds directly at least 10% of the capital of the company paying the dividends.
(pp) The 5% rate applies to sales on credit of industrial, commercial or scientific equipment, and on loans granted by banks. The 10% rate applies in all other cases.
(qq) The 5% rate applies to payments of royalties regarding copyrights of scien tific works, patents, trademarks, secret formulas, processes or information concerning industrial, commercial or scientific experience.
(rr) 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. The 0% rate applies to dividends beneficially owned by a contracting state, a political subdivision, a local authority, an investment authority, the central bank or a pension fund thereof or any other institution or fund that is recognized as an integral part of that state, political subdivision or local authority, as shall be agreed by mutual agreement of the competent authorities of the contracting states.
(ss) This treaty is effective from 1 January 2022.
(tt) The 5% rate applies if the beneficial owner is the “government,” as defined below, of a contracting state. The 10% rate applies if the beneficial owner is a company that holds at least 25% of the capital of the distributing company. Otherwise, the 15% rate applies.
For the purposes of Article 10 “Dividends”, Article 11 “Interest” and Article 13 “Capital gains” of the double tax treaty, the term “government” means the following:
• Political subdivision
• Local authorities
• Central bank
• Any other institution resident in that contracting state performing finan cial functions of a governmental nature and the capital of which is wholly owned directly or indirectly by that contracting state
In the case of Qatar, the institutions referred to above are the following:
• Qatar Investment Authority
• Qatar Holding
• Qatar Development Bank
• Qatar Energy (formerly known as Qatar Petroleum)
• Qatar Retirement Funds (uu) The 0% rate applies if the beneficial owner is the “government” of the other contracting state. The term “government” has the same meaning as defined in footnote (tt) above.
Qatar has ratified tax treaties with Belgium, Eritrea, Fiji, Gambia, Mauritania, Nigeria and Paraguay. The entry into force dates of these treaties is unknown at this stage.
Qatar has signed treaties that are in the process of ratification with Bosnia and Herzegovina, Ethiopia, Ghana and Oman.
Qatar is in the process of negotiating, signing and ratifying tax treaties with Bangladesh, the Czech Republic, Egypt, Estonia, Eswatini, Gabon, Germany, Iceland, Libya, Lithuania, Montenegro, Peru, Tajikistan, Thailand, Turkmenistan, Uruguay and Uzbekistan.
Qatar is renegotiating its tax treaties with India, Morocco and Pakistan.