Article 2 Bis (2) addresses technical service fees arising outside Qatar and paid to a Qatari project. Such fees are subject to Qatari income tax, provided that the recipient project does not operate through a permanent establishment in the foreign jurisdiction where the fees originated. Furthermore, the fees must not be effectively connected to any such foreign permanent establishment. This article, added via Law 11/2022, clarifies the tax treatment of cross-border technical, consultancy, and administrative services rendered by Qatari-resident entities in foreign markets.
SECTION 2 - SCOPE OF TAXATION
Chapter 1 - Tax Liability
Article 2 Bis (2)
Technical service fees arising abroad and paid to a Qatari project are subject to tax, taking into consideration the following:
The Qatari project benefiting from the technical service fees does not conduct business in the foreign country where the technical service fees arise through a permanent establishment there.
The technical service fees are not effectively connected with this permanent establishment.
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