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May 15, 2026

Part 4 - Avoidance of Double Taxation

Chapter 2 - Tax Avoidance between Persons or By Entering into Transactions

Section 2 - Cases of Avoidance by Entering into Transactions

Article 131 bis

[GTL Notes: Enterprise Establishment Avoidance]

In exception from the provisions of Article 130 of this Law, the provisions of Article 131 thereof shall be applied if it is revealed to the Authority that the main objective for any transaction performed by the taxpayer was to avoid subjecting - wholly or partly - to due and payable tax for any tax year through the establishment of one or more establishment in order to benefit from the provisions stipulated in Part Five bis of this Law.