Article 13 - Non Residents

(1) The Chargeable Profits of a QFC Entity not Resident in Qatar shall be the amount of Chargeable Profits as are attributable to its Permanent Establishment in Qatar.
(2) The Chargeable Profits attributable under Article 13(1) to a Permanent Establishment shall be the same as the Chargeable Profits it would have made if it were a distinct and separate entity, engaged in the same or similar activities under the same or similar conditions, dealing wholly independently with the enterprise of which it is a Permanent Establishment.
(3) In attributing Chargeable Profits to a Permanent Establishment under Article 13(2) the Permanent Establishment shall be assumed to have the same credit rating as the enterprise of which it is a Permanent Establishment.
(4) In attributing Chargeable Profits to a Permanent Establishment under Article 13(2) there shall be attributed to the Permanent Establishment such equity and loan capital as appears to the Tax Department to be just and reasonable.
(5) In attributing Chargeable Profits to a Permanent Establishment under Article 13(2), a deduction shall be available to the Permanent Establishment in respect of interest incurred by the enterprise of which it is a Permanent Establishment on indebtedness utilised by the Permanent Establishment in carrying out its activities. If only part of the indebtedness is utilised by the Permanent Establishment in carrying out its activities, a proportion of interest as appears to the Tax Department to be just and reasonable shall be available for deduction.
Amended (as from 18th June 2014)