Cabinet Decision No. 39 of 2019, Article 63, targets indirect profit transfers between related entities. Taxable income must include any profits shifted through artificial price adjustments. This also applies to transactions with unrelated entities if they benefit from preferential tax regimes or are located in non-cooperative jurisdictions. Furthermore, the rule extends to transactions between an entity and its own permanent establishment in the state. By comparing these to hypothetical independent transactions, the Authority can re-calculate and tax the income that would have naturally been realized in Qatar.