Worldwide transfer pricing reference guide 2014

Qatar (continued)
Return disclosures/related party disclosures
State tax regime:
Related party disclosures must be disclosed in the notes to the audited financial statements, which are filed with the PRTD in support of
the tax declaration.
QFC tax regime:
Related party transactions must be disclosed in the notes to the audited financial statements, which are filed with the QFC Tax
Department along with the income tax return.
Transfer pricing-specific returns
State tax regime:
There is currently no requirement to prepare a separate tax return for related party transactions.
QFC tax regime:
There is currently no requirement to prepare a separate tax return for related party transactions.
Frequency of tax audit and transfer pricing scrutiny by the tax authority
State tax regime:
During the income tax review process, the PRTD is likely to demand the documentation supporting the transfer prices for intercompany
transactions to be produced.
The PRTD conducts a tax audit of all tax declarations that are submitted. The likelihood is medium to high.
The likelihood of a review of transfer pricing as part of the regular audit is medium to high.
The likelihood of a challenge to the transfer pricing methodology, however, is characterized as low to medium, provided that sufficient
transfer pricing documentation is available.
QFC tax regime:
In general, the QFC Tax Department conducts a tax audit of income tax returns that are submitted – the likelihood being medium to high.
The likelihood of a review of transfer pricing as part of the regular audit is medium to high.
The likelihood of a challenge to the transfer pricing methodology, however, is characterized as low to medium, provided that sufficient
transfer pricing documentation is available.
APA opportunity
State tax regime:
There is currently no APA procedure in place.
QFC tax regime:
The QFCA Tax Department has an advance ruling regime and welcomes QFC registered entities to apply for an APA to obtain certainty on
its tax position.
Expected reaction to OECD Report on BEPS
So far there has not been any reaction by the State tax regime on BEPS.
The QFC tax regime has not issued any written guidance but it is expected to adopt the recommendations of the OECD on the BEPS
project and cooperate with the international community to address relevant issues.
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