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June 26, 2026

Resolution of President of General Tax Authority No. 4 of 2020 relating to the Transfer Pricing Declaration and Submission of the Master File and Local File

Number of Articles: 12

Contents

Article 1 - Definitions

Chapter 1: Transfer Pricing Declaration

Article 2 - Declaration Submission Requirements

Article 3 - Threshold Requirements

Article 4 - Declaration Filing Procedures

Article 5 - Declaration Information Requirements

Chapter 2: Master File and Local File

Article 6 - Master and Local File Submission Requirements

Article 7 - Master and Local File Threshold Requirements

Article 8 - Master and Local File Submission Deadline

Article 9 - Master File Information Requirements

Article 10 - Local File Information Requirements

Article 11 - Effective Date

Article 12 - Enforcement

President of General Tax Authority,

Having perused Law No. 24 of 2018 issuing the Income Tax Law;

Emiri Resolution No. 77 of 2018 on the establishment of General Tax Authority; and

Cabinet Resolution No. 39 of 2019 issuing the Executive Regulations of Law No. 24 of 2018 issuing the Income Tax Law,

Hereby resolved as follows:

Article 1 - Definitions

Unless the context otherwise requires, the following terms, wherever mentioned throughout this Resolution, shall have the meanings hereby assigned for them:

The "State"

:

means the State of Qatar.

The "Authority"

:

means the General Tax Authority.

The "Group"

:

means the group of associated enterprises and projects.

The "Associated Enterprises"

:

means Associated Enterprises as stated in Article 52 of the Executive Regulations of the Income Tax Law.

The "Declaration"

:

means the Declaration of Transfer Pricing

The "Master File"

:

means a file submitted by a local project related to another project(s), containing standardized information about the associated projects with regard to their business operations and transfer pricing policies.

The "Local File"

:

means a file that provides detailed Transfer Pricing information on a local entity's transactions with Associated Enterprises.

The "Controlled Transactions"

:

means the transactions between two Associated Enterprises.

Chapter 1: Transfer Pricing Declaration

Article 2

Declaration Submission Requirements

The Declaration shall be submitted by:

  1. Associated Enterprises residing in the State; and

  2. Permanent establishments of non-resident Associated Enterprises in the State.

Article 3