By Rubeena Dina, Partner at Global Tax Services – United Arab Emirates & Director at GTS Africa – Mauritius
The General Tax Authority in Qatar has extended until 30 September the deadline for the filing of master files and local files for the fiscal year ending 31 December 2020, through Decision No (8) of 2021 issued on 17 June.
Obligations for fiscal year ended 31 December 2020
Qatar had issued transfer pricing regulations that are effective from 01 January 2020. Under Article (8) of Decision No 4 of 2020, resident entities and permanent establishments of non-resident entities in Qatar must submit transfer pricing documentation in the form of master file and local file if they undertake cross-border related party transactions and have a turnover or total assets of more than Qatari Riyal 50,000,000 (approximately USD 14 million) in the financial year.
The deadline for filing the documentation is six months following the end of the fiscal year, with the first filing obligation set at 30 June 2021.
The extension issued on 17 June is an exception to the provisions of Article (8) and will provide taxpayers with more time to collect and collate their documentation.
However, there has been no change with regards to the filing of the disclosure form, which should have been submitted on the same day as the corporate annual income tax return, i.e., 30 April 2021.
The objective of the master file is to provide the General Tax Authority with high-level information regarding the global business operations and transfer pricing policies of a taxpayer. The local file, on the other hand, is designed to provide detailed transactional information within a certain jurisdiction.
The General Tax Authority requires taxpayers to articulate consistent transfer pricing positions, so that it can effectively identify and evaluate transfer pricing risks of taxpayers and transactions.
Taxpayers have been given additional time to prepare the first submission of master files and local files, which is expected to be more time-consuming than in subsequent years. It is recommended that taxpayers use the additional time to ensure that they prepare robust documentation to support their transfer pricing policies.