Article 10 - Local Source

(1) Taxable Profits are Local Source if they arise in or are derived from Qatar.
(1A) Notwithstanding any other provisions in these Regulations, profits arising in or derived from Qatar by a QFC Entity that is not an Authorised Firm from the provision of services for use outside Qatar are deemed not to be Local Source Taxable Profits to the extent that the conditions set out in Rule 1A are met.
(2) Without prejudice to the generality of Article 10(1), Local Source Taxable Profits are deemed to include—
(a) Passive Interest Income; and
(b) notwithstanding the provisions of Article 13, profits arising from interest income received by or accrued to a Financial Institution to the extent that—
(i) the profits are attributable to the initiation of the underlying loan in Qatar by, or on behalf of, the Financial Institution ; and
(ii) the risk of default in respect of either (or both) the interest and principal of the loan is borne by the Financial Institution in Qatar,
provided that where either condition (i) or (ii) is met, but not both, 50% of the relevant profits shall be deemed to be Local Source Taxable Profits.
(3) Local Source Taxable Profits shall exclude any profit derived from—
(a) immovable property located outside Qatar;
(b) Permanent Establishments of the QFC Entity outside Qatar; and
(c) notwithstanding Article 10(2)(a), the receipt of Passive Interest Income where the borrower is not Resident in Qatar (and the borrowing is not substantially undertaken by or through a Permanent Establishment of the borrower in Qatar) or where the borrower is Resident in Qatar and the borrowing is substantially undertaken by or through a Permanent Establishment of the borrower outside Qatar.
Amended (as from 12th June 2017).