Article 2 Bis (1), introduced by Law 11/2022, expands the scope of taxation to include distributed profits, interest, and royalties arising abroad and paid to a Qatari project. These incomes are taxable provided the Qatari project does not conduct business through a permanent establishment in the country where the income arose. Additionally, the underlying rights, debt claims, or property generating the income must not be effectively connected to such a permanent establishment. This provision ensures that foreign passive income is captured within the Qatari tax net under specific anti-avoidance conditions.
SECTION 2 - SCOPE OF TAXATION
Chapter 1 - Tax Liability
Article 2 Bis (1)
Distributed profits paid by a foreign company resident abroad to a Qatari project are subject to tax, as are interest and royalties arising abroad and paid to a Qatari project, taking into consideration the following:
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