• The Transfer Pricing requirements include four tiers of compliance: (i) Transfer Pricing Form/Questionnaire to be provided with the Tax Return, (ii) Masterfile, (iii) Local file and (iv) Country by Country Reporting requirements (already introduced in 2018/2019).
• Preparing TP documentation (Local File and Master File) by the time of filing the tax return for the period of occurrence of the respective related party transaction(s) or at any other date that the GTA may specify otherwise. Master file is the responsibility of the parent company at the group level to provide the data to the local entity.
• The Local File and Master File shall be established according to the OECD Guidelines. The GTA did not establish a specific format/template for this purpose and to the extent that the following conditions are met:

For both the Local and Master File:

1. Providing guidance to clients on the implementation of an efficient managerial accounting system.
2. Ensuring that the prescribed threshold criteria (with a total revenue or total assets exceeding QR 50,000,000) are met.
3. Having at least one affiliated party situated beyond the borders of Qatar.

For Disclosure Form on Transfer Pricing:

1. Providing advice to clients on the implementation of an efficient managerial accounting system.
2. Ensuring that the prescribed threshold criteria, with total revenue or total assets QR 10,000,000 till QR 50,000,000 are met.
3. Having at least one affiliated party situated beyond the borders of Qatar.

• GTA will request the entity to provide any necessary documents to support the subject matter. The deadline for the taxpayer to provide such information upon request from the GTA shall not exceed 30 days from the date of the GTA's request.
• GTA will no longer accept the absence of a Local file / Master File, based on the argument that other companies of the group are responsible for establishing and documenting the arm's length principle. Also, the absence of adjustment to the intercompany prices in case such prices are not established to be arm's length.
• As per the transfer pricing provisions pertaining to Executive Regulations, the calculation of the arm’s length price has to be done by using Comparable Uncontrolled Price (CUP) methodology as the primary method. In the event the CUP method is not applicable, the taxpayer should lodge a request to the GTA for the application of a different transfer pricing methodology as prescribed in the OECD guidelines.
  
  
• Comparable Uncontrolled Price (‘CUP’) Method.
  
  
  • Resale Price Method (‘RPM’).
  • Cost Plus Method (‘CPLM’).
  • Profit Split Method (‘PSM’). or
  • Transactional Net Margin Method (‘TNMM’).

With our TP expert our firm can undertake and perform the following activities:

1. Performance of functional analysis in the intra-group transactions through meetings and interviews with the Group’s management.
2. Performance of the necessary economic analyses to check and be able to support the arm’s length nature of material intra-group transactions. The analyses will be performed by applying the most appropriate TP method to the circumstances of the cases according to the OECD TP Guidelines.
3. In absence of comparable uncontrolled transactions, in order to test the arm’s length nature of certain intra-group transactions, it may be necessary to carry out certain benchmarking analyses through external databases.
4. Drafting of TP documentation in line with the standards set forth by the OECD TP Guidelines, illustrating the analyses performed and the conclusions reached about the arm’s length nature of each material intra-group transactions.