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:
The Qatari project benefiting from the distributed profits, interest, or royalties does not conduct business in the foreign country where the distributing company is resident or where the interest or royalties arose, through a permanent establishment there.
The shares, quotas, or other rights on which the distributed profits are paid, the debt claims on which the interest is paid, or the rights or property on which the royalties are paid, are not effectively connected with this permanent establishment.
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