Article 2 Bis (4) provides a specific exemption for profits attributable to a permanent establishment (PE) through which a Qatari project conducts business in a foreign country. These profits are not subject to tax in Qatar, provided they are subject to tax in the foreign jurisdiction where the PE is located. This rule, added by Law 11/2022, acts as a mechanism to avoid double taxation on active business income earned abroad, ensuring that the Qatari state respects the taxing rights of the host country for local business operations.
SECTION 2 - SCOPE OF TAXATION
Chapter 1 - Tax Liability
Article 2 Bis (4)
If a Qatari project conducts business in a foreign country through a permanent establishment there, the profits attributable to the permanent establishment are not subject to tax, provided they are subject to tax in that foreign country.
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