Transfer pricing in Qatar for SMEs and branches

The short answer

What transfer pricing means for a Qatar company

Transfer pricing is the price and terms set for dealings between related parties. The Income Tax Law defines the arm’s length principle as the terms that independent enterprises would agree in similar transactions and circumstances (Article 1).

Related, or “linked”, entities are those defined by international accounting standards, in practice IAS 24 (Executive Regulations Article 52).

In Qatar, the common examples are goods bought from or sold to a shareholder’s or sister company, and services, management fees and shared costs charged within a group. Loans and guarantees from a parent or shareholder are also covered, as are royalties for a brand, software or know-how owned elsewhere in the group, and charges between a branch and its foreign head office.

The rules that apply to every company, whatever its size

Most of the transfer pricing rules in the Executive Regulations have no size test and no foreign test. A company below QAR 10 million with only Qatari sister companies is still covered.

Prices with linked entities must be set at arm’s length using reasonably available information, assessed at the time of the transaction and at the latest when the return is filed (Article 53). Every linked entity takes transfer pricing into account and reports the resulting income in its return (Article 52), together with its functions, risks and assets (Article 54). The company must then be able to show with sufficient documents that its prices are at arm’s length. Blaming another group company is no defence, and even full documents do not prevent an adjustment (Articles 59 to 62).

If profit is shifted to a related entity, it is added back to taxable income, and the same applies to profit shifted to an unrelated party under a preferential regime or in a non-cooperative jurisdiction (Article 63; Income Tax Law Article 33). A company that attaches audited accounts to its return also includes a schedule of transactions with related parties (Article 34(2)(g)); see is an audit mandatory in Qatar. Interest to related parties is deductible only on loans up to three times equity, with an agreement stating the term and purpose (Article 10). See tax deductions and depreciation in Qatar.

What to file, by size of company

For a 31 December year end, the return and the declaration are due by 30 April, and the master file and local file for 2026 by 30 June 2027. See the Qatar compliance calendar 2027. When the GTA extends the return deadline, check whether the extension also covers these documents.

The transfer pricing declaration

Resident associated enterprises, and permanent establishments of non-resident ones, file the declaration where annual turnover or total assets are QAR 10 million or more (Resolution 4/2020, Articles 2 and 3). It is filed in the same form and manner, and on the same date, as the tax return (Article 4). The Dhareeba FAQ describes it as submitted with the annual return.

Under Article 5 the declaration covers:

• the group’s activity, its main intangible assets and where they are owned, and its transfer pricing policy;
• the company’s own activity;
• a brief statement of transactions with related parties above QAR 200,000, with their nature, amount and the counterparty’s country;
• the main transfer pricing method used for each type of transaction.

Only the state or territory of each related party is reported, not its name or address (Dhareeba FAQ). The Regulations name no required method; the declaration asks which method you used, such as the comparable uncontrolled price or resale price method. For filing the return itself, see how to file a corporate income tax return and our corporate income tax return service.

Master file and local file

Both files are needed only where two tests are met: turnover or total assets of QAR 50 million or more, and at least one group entity resident outside Qatar (Resolution 4/2020, Articles 6 and 7; Executive Regulations Article 57). They are due no later than 30 June of the year after the reported year (Resolution Article 8).

The files follow the OECD format, unless the GTA adopts its own (Regulations Article 57). The master file gives the group picture, covering its structure, business, intangibles, financing and transfer pricing policies (Resolution Article 9). The local file deals with the Qatar entity, its controlled transactions and how each price was set, and it comes with audited financial statements (Resolution Article 10).

Not every transaction needs to be described. Controlled transactions are aggregated by category and described where a category exceeds QAR 200,000 a year, including head office and branch dealings, and amounts are shown gross, with no netting (Dhareeba FAQ). Comparables are updated each year, with the database search renewed every three years if business conditions are unchanged (Regulations Article 55). Where no comparable data exists or a search would cost too much, the taxpayer need not incur that cost (Dhareeba FAQ).

The GTA can ask for more information within a maximum of 30 days and can issue a questionnaire (Regulations Article 56). Our transfer pricing service covers the local file and supporting analysis.

Branches of foreign companies

A branch is a permanent establishment, so it is counted for both thresholds (Resolution 4/2020, Articles 2 and 6). Its profit is measured as if it were a separate enterprise dealing independently with its head office (Executive Regulations Article 7(2)).

The branch may deduct the real expenses of its activity, including executive and general administrative costs incurred in Qatar or abroad. It may not deduct royalties, fees, commissions, management charges or interest paid to head office, other than actual reimbursement of costs, except in the case of banks (Article 7(3)). Profit shifted between an entity and its permanent establishment can be added to taxable income (Article 63), and in the local file, head office and branch dealings above the QAR 200,000 category line are described (Dhareeba FAQ).

See running a branch of a foreign company in Qatar, withholding tax in Qatar for fees and royalties paid abroad, and our page on foreign company branches.

Country-by-country reporting in brief

Groups with consolidated revenue below QAR 3 billion in the preceding fiscal year are exempt. A report is due within 12 months of the fiscal year end, and Qatar group entities that are not the parent file only in the cases the Decision lists (Minister of Finance Decision No. 16 of 2019, Articles 1, 2 and 5). Under GTA Circular No. 10 of 2020, only a Qatar-resident ultimate parent notifies the GTA; a Qatar subsidiary of a foreign group does not. Reports are filed on the GTA’s Tabadol portal. Pillar Two, for groups of EUR 750 million or more, is separate; see Pillar Two in Qatar.

A related-party checklist for small groups

1. 1

   List related parties

   Name each related party under IAS 24 and its country.

2. 2

   List transactions

   Group them by category and total each one for the year.

3. 3

   Check the thresholds

   Test turnover and total assets against QAR 10 million and QAR 50 million.

4. 4

   Put agreements in writing

   Especially loans, guarantees, service charges and cost sharing.

5. 5

   Record how each price was set

   Keep the comparison or cost basis used at the time of the transaction.

6. 6

   Test related-party interest

   Compare loans with three times equity.

7. 7

   Prepare the related-party schedule

   Attach it with the audited accounts and the tax return.

8. 8

   Diary the dates

   The return date and, where in scope, 30 June.

9. 9

   Review every year

   Update comparables yearly and renew searches every three years.

Our tax advisory service includes a health check of related-party dealings before the GTA asks.

What to do next

Start with the list of related parties and transactions, then check which row of the table above applies to you. Our transfer pricing page describes how we help prepare the declaration, the master file and the local file. To discuss your group, request a proposal.

Frequently asked questions

Sources

This article is general information, not tax advice for your company. The laws, resolutions and GTA pages cited were checked on 16 October 2026; English descriptions of Arabic legal texts are our own. Entities in the Qatar Financial Centre follow QFC rules, which this article does not cover.

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