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Qatar

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Qatar can legally issue the following five types of rulings within the scope of the transparency framework: (i) preferential regimes; Rulings issued in relation to certain exemptions and concessionary rate under the Qatar Financial Centre (QFC) Tax Regulations. (ii) cross-border unilateral APAs and any other cross-border unilateral tax rulings (such as an advance tax ruling) covering transfer pricing or the application of transfer pricing principles; (iii) rulings providing for unilateral downward adjustments; (iv) permanent establishment rulings; and (v) related party conduit rulings.

Qatar’s legal framework implementing the AEOI Standard is in place and is consistent with the requirements of the AEOI Terms of Reference. This includes Qatar’s domestic legislative framework requiring Reporting Financial Institutions to conduct the due diligence and reporting procedures (CR1) and its international legal framework to exchange the information with all of Qatar’s Interested Appropriate Partners (CR2).

Qatar can legally issue the following five types of rulings within the scope of the transparency framework: (i) preferential regimes; Qatar financial centre (QFC). (ii) cross-border unilateral APAs and any other cross-border unilateral tax rulings (such as an advance tax ruling) covering transfer pricing or the application of transfer pricing principles; (iii) rulings providing for unilateral downward adjustments; (iv) permanent establishment rulings; and (v) related party conduit rulings.

Qatar was reviewed as part of the 2017/2018 and the 2018/2019 peer reviews. This report is supplementary to those previous reports (OECD, 2019[1]) (OECD, 2018[2]).

Le Qatar compte 77 conventions fiscales en vigueur, comme l’indique sa réponse au questionnaire d’examen par les pairs. Sa convention avec le Ghana* est conforme au standard minimum.

English

Qatar has 77 tax agreements in force, as reported in its response to the Peer Review questionnaire. Its agreement with Ghana* complies with the minimum standard

French

This peer review covers Qatar’s implementation of the BEPS Action 5 transparency framework for the year 2018. The report has four parts, each relating to a key part of the ToR. Each part is discussed in turn. A summary of recommendations is included at the end of this report.

Qatar was first reviewed during the 2017/2018 peer review. This report is supplementary to Qatar’s 2017/2018 peer review report (OECD, 2018[1]). The first filing obligation for a CbC report in Qatar applies to reporting fiscal years commencing on or after 1 January 2018. In principle, an Ultimate Parent Entity of an MNE Group that is resident in Qatar is required to file a CbC report in Qatar for fiscal years commencing between 1 January 2017 and 31 December 2017. However, this obligation is waived in circumstances where the MNE Group files a CbC report for the fiscal year in another jurisdiction via a surrogate parent entity in that jurisdiction, and certain conditions are met.

1. Consistent with the agreed methodology this first annual peer review covers: (i) the domestic legal and administrative framework, (ii) certain aspects of the exchange of information framework as well as (iii) certain aspects of the confidentiality and appropriate use of CbC reports. Qatar’s implementation of the Action 13 minimum standard meets all applicable terms of reference, except that it raises one interpretive, one timing and one substantive issue in relation to its domestic legal and administrative framework. The report, therefore, contains three recommendations to address these issues. In addition, it is recommended that Qatar complete the exchange of information framework as well as measures to ensure appropriate use. Qatar indicates that there is a commitment of the tax department to postpone the CbC requirements in Qatar to 1 January 2017.

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