Welcome back to our two-part guide on Transfer Pricing in Qatar, brought to you by HLB AG, one of Qatar’s leading audit and advisory firms. In Part 1, we covered the foundational 25 questions related to compliance, documentation, and regulatory requirements.

In this continuation, we answer questions 26 to 50, focusing on practical challenges, strategic planning, and how HLB AG supports businesses across industries. Whether you’re a multinational or a local enterprise engaging in cross-border transactions, this part offers expert insights to help you stay compliant and future-ready.

Section 4: Compliance & Challenges

Understanding transfer pricing regulations is one thing; but ensuring day-to-day compliance is where most businesses struggle. In this section, we tackle the most frequent challenges companies face in Qatar, from data limitations to managing related-party financing.

26. Can documentation be outsourced?

 Yes. HLB AG provides full documentation and advisory services.​

27. What are the top challenges businesses face?

• Lack of comparable data
  
• Constant regulatory updates
  
• Limited in-house expertise

28. Are related-party loans subject to transfer pricing?

Yes. Interest rates must meet arm’s length criteria.

29. What about intangible assets?

They must be priced based on value creation and usage rights.
DEMPE analysis (Development, Enhancement, Maintenance, Protection and Exploitation) should be carried out to determine which entities should receive the economic benefits from the intangible asset. Legal owner may not be the economic owner. To allocate the return arising from intangible, it is essential to identify the economic owner. As such DEMPE function is important.

30. What is a Transfer Pricing policy?

An internal document outlining principles and methodology used by a group.

31. Should the TP policy be shared with auditors?

 Yes. It helps in tax and statutory audits.

32. How are management fees treated?

They must be supported by actual service rendered and market comparables.

33. What happens if a company doesn’t have comparables?

 HLB can help create internal comparables or use global benchmarks.

34. Can you appeal penalties?

 Yes. GTA and QFC allow for administrative appeals with proper justification.

35. Are disclosures confidential?

 Yes. The GTA maintains strict data privacy standards.

Section 5: Strategic Planning & Future Outlook

Beyond compliance, transfer pricing should be viewed as a strategic tool. When implemented correctly, it can enhance tax efficiency, reduce risks, and support international expansion. This section explores how businesses can align policies with long-term goals while staying ahead of evolving Qatari regulations.

36. How to prepare for audits?

 Maintain thorough documentation, conduct mock audits, and consult HLB experts.

​37. Are APAs available in Qatar?

 As of now, Qatar does not have a formal APA program.

​38. How to manage dual taxation risks?

 Use of tax treaties and proper TP documentation can help mitigate double taxation.

​39. What’s the future of TP in Qatar?

 Increased scrutiny, alignment with BEPS, and digitization of filings.

40. What are intercompany agreements?

 Legal contracts that formalize pricing, terms, and conditions between entities.

41. How is economic substance linked to TP?

Both require alignment between operations, management, and reporting.

42. Is ERP integration recommended?

Yes. Automating data capture simplifies documentation.

43. Does the group HQ’s tax residency affect TP?

Yes. HQ in low-tax jurisdictions may invite more scrutiny. 

Qatar has published Law No. 22 of 2024 amending certain provisions of Income Tax Law No. (24) of 2018.  Law No. 22 of 2024 introduces a local supplementary minimum tax (Domestic Minimum Top-Up Tax) and a local Income Inclusion Rule that will apply to multinational enterprises operating in Qatar with a consolidated annual revenue amounting to or exceeding EUR 750 million in two of the last four fiscal years aligned with the GloBE Model Rules. The provisions of Law No. 22 of 2024 are effective from 1 January 2025 and apply to all areas of Qatar, including the Qatar Science and Technology Park.

44. How often should policies be reviewed?

Annually, or with any operational/market changes.

45. Do you need TP advisory when expanding into Qatar?

Absolutely. HLB AG offers strategic advice for new entrants.

Section 6: How HLB AG Can Help

Having the right partner is critical for navigating transfer pricing complexities. This final section showcases how HLB AG empowers businesses through tailored solutions—from risk assessments and documentation to audit representation and proactive planning.

46. What makes HLB AG different in Qatar?

• Local expertise backed by global standards
  
• Tailored advisory for SMEs and multinationals
  
• End-to-end documentation, compliance, and training support

47. Is industry-specific advice available?

Yes. HLB supports sectors like construction, retail, finance, and energy.

48. Can HLB support in tax audits related to TP?

Yes. They represent clients before the GTA or QFC and help in resolution.

49. Does HLB AG only serve large clients?

No. Solutions are designed for startups to large conglomerates.

50. How do I get started with HLB AG?

 Click here to explore HLB AG’s Transfer Pricing Services.

Final Words

Transfer pricing is not just about compliance—it’s a strategic pillar of tax management. With growing regulatory scrutiny in Qatar, having a knowledgeable partner like HLB AG ensures you're always prepared, protected, and positioned for growth. For accurate documentation, effective planning, and full support, visit: HLB AG Transfer Pricing Services

©2025 Antonio Ghaleb and Partner CPA and HLB AG-Members of HLB. All rights reserved. These highlights have been prepared for general guidance on matters of interest only and do not constitute professional advice. You should obtain professional advice before taking action on the information contained in these highlights. Antonio Ghaleb and Partner CPA and its employees do not give any representation or warranty (express or implied) regarding the accuracy or completeness of the information contained in these highlights. Antonio Ghaleb and Partner CPA and its employees do not assume any responsibility, liability, duty of care for any negative consequences that may result in reliance to these highlights and for any decision based on them.