QFC Tax Regulations

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QFC Tax Regulations
Enactment Notice
Part 1:
Application, Commencement and Interpretation
Article 1 - Citation
Article 2 - Application
Article 3 - Commencement
Article 4 - Language
Article 5 - Interpretation
Part 2:
General Scheme of Taxation, Residence and the Charge to Tax
Article 6 - Policy Statement on the General Scheme of Taxation
Article 7 - Scope of Regulations
Article 8 - Residence and Non-Residence
Article 9 - The Charge to Tax
Article 10 - Local Source
Article 11 - Taxable Profits and Chargeable Profits
Article 12 - Currency of Tax Calculation
Article 13 - Non Residents
Part 3:
Accounting Profit and Accounting Periods
Article 14 - Policy Statement on Accounting Profit and Accounting Periods
Article 15 - Accounting Profit
Article 16 - Change in Basis of Accounting
Article 17 - Accounting Period
Article 18 - Deemed Disposals
Part 4:
Computational Provisions
Article 19 - Policy Statement on Computational Provisions
Article 20 - Scope of Charge
Article 21 - Deductions Not Allowable and Charitable Donations
Article 22 - Depreciation
Article 23 - Limits on Depreciation
Article 24 - Amortisation of Intangible Fixed Assets
Article 25 - Share Based Remuneration
Part 5:
Loss Relief
Article 26 - Policy Statement on Loss Relief
Article 27 - Calculation of Tax Losses
Article 28 - Carry Forward of Tax Losses
Article 29 - Transfer of Licensed Activity Without Change in Ownership
Article 30 - Disallowance of Tax Losses on a Change in Ownership
Article 31 - Determination of Change in Ownership
Article 32 - Group Relief
Article 33 - Corresponding Accounting Periods
Article 34 - Definition of a Group
Article 35 - Companies Joining or Leaving a Group
Part 6:
Double Taxation Relief
Article 36 - Policy Statement on Double Taxation Relief
Article 37 - Relief Under Agreements with Other Countries
Article 38 - Unilateral Relief
Article 39 - Calculation of Income Subject to Overseas Tax
Article 40 - Election to Treat as an Expense
Part 7:
Reorganisations and Reconstructions
Article 41 - Policy Statement on Reorganisations and Reconstructions
Article 42 - Intra-Group Transfer of Assets
Article 43 - Replacement of Business Assets
Article 44 - Reduction in Share Capital
Article 45 - Incorporation of a Business
Article 46 - Reorganisations and Reconstructions Carried out for Bona Fide Commercial Reasons
Part 8:
Transfer Pricing
Article 47 - Policy Statement on Transfer Pricing
Article 48 - Basic Rule
Article 49 - Loans
Article 50 - Guarantees
Article 51 - Compensating Adjustment Claims
Article 52 - Compensating Adjustment for Guarantor
Article 53 - Balancing Payments
Article 54 - Balancing Payments by Guarantor
Article 55 - Effect on Double Taxation Relief
Article 56 - Associated Persons
Article 57 - Control
Article 58 - Transfer Pricing Appeals
Article 59 - Supplementary Provisions
Part 9:
General Partnerships and Limited Partnerships
Article 60 - Policy Statement on General Partnerships and Limited Partnerships
Article 61 - General Scheme for Limited Partnerships and General Partnerships
Article 62 - Payment of Tax and Computation of Chargeable Profits of Limited Partnerships and General Partnerships
Part 10:
Limited Liability Partnerships
Article 63 - Policy Statement on LLPs
Article 64 - General Scheme for LLPs
Article 65 - Computation of Chargeable Profits of LLPs
Part 11:
Islamic Finance
Article 66 - Policy Statement on Islamic Finance
Article 67 - Taxation of Islamic Financial Institutions
Article 68 - Funding Costs of Islamic Financial Institutions
Article 69 - Taxation of Islamic Finance Transactions
Article 70 - Islamic Finance and Special Purpose Company
Part 12:
Participation Exemptions
Article 71 - Policy Statement on Participation Exemptions
Article 72 - Participation Exemption on Investment in Shares
Article 73 - Interaction between Article 42 and Article 72
Part 13:
Insurance Companies
Article 74 - Policy Statement on Insurance Companies
Article 75 - Taxation of Insurers
Article 76 - Provisions
Article 77 - Takaful
Article 78 - QFC Captive Insurers
Article 79 - Reinsurers
Article 80 - Cessation of Business
Part 14:
Special Exemptions
Article 81 - Policy Statement on Special Exemptions
Article 82 - Election for Special Exempt Status
Article 83 - Registered Fund
Article 84 - Special Investment Fund
Article 85 - Special Funding Company
Article 86 - Alternative Risk Vehicles
Part 15:
Concessionary Rate
Article 87 - Policy Statement on the Concessionary Rate
Article 88 - Election for the Application of the Concessionary Rate
Article 89 - Qatari Owned QFC Entity
Article 90 - Concessionary Rate
Article 91 - Concessionary Rate Charge
Article 92 - Apportionment of Chargeable Profits
Part 16:
Credit for Tax Losses
Article 93 - Policy Statement on Credit for Tax Losses
Article 94 - Credit for Tax Losses
Article 95 - Reimbursable Tax Losses
Article 96 - Payment of Reimbursable Tax Losses
Article 97 - Requirement for QFC Entity to be a Going Concern
Article 98 - Restriction on Carry Forward of Tax Losses and Group Relief where a Tax Credit is Claimed
Article 99 - Artificial Arrangements
Article 100 - Restriction to Elect for Special Exempt Status or for the Concessionary Rate
Part 17:
Administration
Article 101 - Establishment of the Tax Department
Article 102 - Power to Delegate
Article 103 - Power to Make Rules
Part 18:
Rulings by Tax Department
Article 104 - Policy Statement on Rulings
Article 105 - Rulings
Article 106 - Practice Notes
Part 19:
Records and Returns
Article 107 - Policy Statement on Records and Returns
Article 108 - Records
Article 109 - Obligation to File a Return
Article 110 - Partnership Return
Article 111 - Filing Date
Article 112 - Self-Assessment
Article 113 - Calculation of Tax Payable
Article 114 - Claims
Article 115 - Prescribed Form and Information to Accompany Return
Article 116 - Amended Returns
Article 117 - Acknowledgement of Returns
Article 118 - Obvious Errors
Article 119 - Financial Sanctions Relating to Returns
Part 20:
Enquiries
Article 120 - Policy Statement on Enquiries
Article 121 - Notice of Enquiry and Notice of Intention not to Enquire
Article 122 - Scope of Enquiry
Article 123 - Amendment of Self-Assessment During Enquiry to Prevent Loss of Tax or Overpayment of a Tax Credit
Article 124 - Completion of Enquiry
Article 125 - Notice to Produce Documents and Information
Article 126 - Amendment of Return by QFC Entity During Enquiry
Part 21:
Assessments
Article 127 - Policy Statement on Assessments
Article 128 - Discovery Assessments and Determinations
Article 129 - Time Limits for Assessments
Article 130 - Error or Mistake
Article 131 - Assessment Procedure
Part 22:
Appeals
Article 132 - Policy Statement on Appeals
Article 133 - Appeal Procedure
Article 134 - Tax Department Review
Article 135 - Appeals
Article 136 - Late Appeals
Part 23:
Information Powers
Article 137 - Policy Statement on Information Powers
Article 138 - Notice to Obtain Information
Part 24:
Payment and Recovery
Article 139 - Policy Statement on Payment and Recovery
Article 140 - Due and Payable Date
Article 141 - Recovery of Overpayment
Article 142 - Collection and Recovery
Article 143 - Late Payment of Tax Charge
Article 144 - Compensation for Overpayment of Tax
Article 145 - Tax Treatment of Charges and Compensation Under Articles 143 and 144
Article 146 - Due and Payable Date in Respect of an Overpayment of a Tax Credit
Part 25:
Financial Sanctions
Article 147 - Criminal Proceedings
Article 148 - Determination of Financial Sanction
Part 26:
Miscellaneous and Supplemental
Article 149 - Responsibility of Representatives
Article 150 - Dividend Exemption and Exempt Returns on Public Treasury Bonds
Article 151 - Government Exemption
Part 27:
Interpretation and Definitions
Article 152 - Interpretation
Article 153 - Definitions