Law No. (24) of 2018 Promulgating the Income Tax Law

Law No. (24) of 2018 Promulgating the Income Tax Law

We Tamim bin Hamad Al Thani, Emir of the State of Qatar, Having reviewed the Constitution, And the Income Tax Law issued by Law No. (21) of 2009, And Law No. (17) of 2014 exempting the share of non-Qatari investors in the profits of some companies and investment funds from income tax, And the Financial System Law of the State issued by Law No. (2) of 2015, And Emiri Decision No. (77) of 2018 establishing the General Tax Authority, And upon the proposal of the Minister of Finance, And upon the draft law submitted by the Council of Ministers, And after taking the opinion of the Shura Council,

We have decided the following Law:

Article (1) The provisions of the Income Tax Law attached to this Law shall be applied.

Article (2) Without prejudice to the provisions of Articles (9 paragraph two / item 2), (13) of the attached Law, the provisions of the attached Law shall not apply to the following:

1. Ministries, government agencies, public bodies, and public institutions.
2. International organizations, their offices, and branches operating in the State.
3. Private associations, private institutions, private charitable associations, and private institutions of public benefit, established in accordance with the provisions of the law regulating any of them.
4. Salaries, wages, allowances, and anything similar to them.
5. Total income from estates and inheritances.

Article (3) The Council of Ministers shall issue, upon the proposal of the Minister of Finance, the Executive Regulation for the attached Law. The Minister of Finance shall issue the necessary decisions to implement its provisions, and until those regulations and decisions are applied, the currently effective regulations and decisions shall continue to apply insofar as they do not conflict with the provisions of the attached Law.

Article (4) Law No. (21) of 2009 and Law No. (17) of 2014, referred to above, are repealed, as is every provision that conflicts with the provisions of this Law and the attached Law. Tax exemptions in effect on the date of applying the attached Law shall continue to apply until their specified periods expire.

Article (5) All competent authorities shall implement this Law, each within its respective jurisdiction. This Law shall be applied from the date of its issuance and published in the Official Gazette.

Tamim bin Hamad Al Thani Emir of the State of Qatar

Issued on: 6 / 4 / 1440 AH Corresponding to: 13 / 12 / 2018 AD

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Income Tax Law

Chapter One Definitions Article (1) In applying the provisions of this Law and its Executive Regulation, the following words and expressions shall have the meanings indicated alongside them, unless the context requires otherwise: Tax: The Income Tax. Minister: The Minister of Finance. Authority: The General Tax Authority. President: The President of the Authority. Activity: Profession, trade, service, commerce, industry, partnership, contracting, or any work aimed at achieving profit or income, including the exploitation of movable and immovable property. Taxpayer: Any natural or legal person subject to tax, in accordance with the provisions of this Law. Responsible Person: The Chairman of the Board, the Managing Director, the Authorized Manager, or any person representing, operating, or managing the company or establishment. Tax Year: Twelve months starting from January 1 and ending on December 31 of the same year. Accounting Period: The period for which the taxpayer prepares its accounts. Total Income: The sum of the taxpayer's income and profits arising from the sources specified in this Law. Net Income: Total Income after deducting allowable deductions, in accordance with the provisions of this Law. Taxable Income: Net Income after deducting losses stipulated in Article (7) of this Law. Return: A statement in which the taxpayer declares the Taxable Income and the amount of tax due, according to the form prepared for this purpose. Resident:

1. A natural person who meets any of the following conditions: a. If he has a permanent residence in the State. b. If he resides in the State for a period exceeding one hundred and eighty-three consecutive or non-consecutive days during (12) twelve months. c. If the center of his vital interests is in the State.
2. A legal person who meets any of the following conditions: a. If it was established in accordance with Qatari legislation. b. If its headquarters is in the State. c. If the center of its main or actual management is in the State. Permanent Establishment: A fixed place through which the taxpayer carries out all or part of its activities, including, for example, a branch, office, factory, workshop, mine, oil or gas well, quarry, construction site, assembly project, or a place for exploring or extracting or exploiting natural wealth resources. A permanent establishment also includes the activity carried out by the taxpayer through a person acting on its behalf or for its benefit, other than an agent of independent status. Royalties: Amounts paid, regardless of their nature, in consideration for the use of, or the right to use, copyrights of literary, artistic, or scientific works, including films, tapes, or discs used for radio or television broadcasting, patents, trademarks, drawings, models, designs, secret processes, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial, or scientific experience. Regulation: The Executive Regulation of this Law.

Chapter Two Scope of Application of Tax Section One Tax Liability Article (2) An annual tax shall be imposed on the total Taxable Income of the taxpayer, arising from sources in the State during the previous Tax Year. As an exception to the preceding paragraph, the tax shall be imposed on:

1. Interest and banking returns accrued outside the State, provided they result from amounts arising from the taxpayer's activity therein.
2. Commissions due under agency, brokerage, or commercial representation agreements, which accrued outside the State for activities carried out therein.

Article (3) Income accrued in the State includes the following:

1. Total Income arising from an activity conducted in the State.
2. Total Income arising from contracts executed wholly or partially in the State.
3. Total Income arising from real estate located in the State, and capital gains arising from their disposal.
4. Total Income arising from shares or stakes of resident companies in the State or listed on their financial markets, and capital gains arising from their disposal.
5. Payment for services paid to headquarters, main offices, branches, or affiliated companies.
6. Interest on loans obtained in the State.
7. Total Income arising from the exploration, extraction, or exploitation of natural resources located in the State.
8. Total Income subject to tax in the State based on a tax treaty. All of the above shall be as specified by the Regulation.

Section Two Tax Exemptions Article (4) Without prejudice to tax exemptions provided for by special laws or international agreements, or those determined in accordance with the provisions of Article (35) of this Law, the following incomes shall be exempt from tax:

1. Interest and banking returns due to natural persons who do not conduct a taxable activity in the State, whether they are residents or non-residents thereof.
2. Interest and returns on government debt papers and Islamic financial instruments, issued in accordance with the provisions of the Financial System Law of the State, and bonds of public bodies and institutions.
3. Capital gains arising from the disposal of real estate or securities, achieved by natural persons, provided that the real estate or securities disposed of do not belong to the assets of a taxable activity.
4. Capital gains arising from the revaluation of a company's assets when presented as a capital contribution in kind for the share capital of a resident joint-stock company in the State, provided that the shares corresponding to the capital contribution in kind are nominal and are not disposed of before five years have passed.
5. Dividends and other income arising therefrom, if the amounts distributed during the Tax Year are withheld from: a. Profits that were subject to tax under the provisions of this Law. b. Profits distributed by a company, the profits of which are exempt from tax under the provisions of this Law or other laws.
6. Total Income arising from craft activities that do not use machines, the income of which does not exceed two hundred thousand Riyals per year, and the average number of their workers does not exceed three workers, and which are conducted through a single establishment. The conditions of the exemption stipulated in this item may be amended by a decision of the Council of Ministers, upon the proposal of the Minister.
7. Total Income arising from agricultural or fishing activities.
8. Total Income achieved by non-Qatari air or sea navigation companies operating in the State, subject to reciprocity.
9. Total Income of Qatari natural persons resident in the State.
10. Total Income of legal persons resident in the State and wholly owned by Qatari nationals.
11. Profits of legal persons resident in the State by the percentage of profits of the following persons therein: a. Qatari natural persons. b. Legal persons wholly owned by Qatari nationals. c. Legal persons partially owned by Qatari nationals by the percentage of their profits therein. The provisions of this item shall not apply to the profit shares of legal persons owned by the State, wholly or partially, directly or indirectly, and operating in the field of petroleum operations and petrochemical industries.
12. Total Income arising from activities authorized for private bodies registered in the State, or registered in another state and licensed to work in the State, to the extent of their non-profit-oriented activities.
13. The share of the non-Qatari investor in the profits of companies whose shares are listed for trading on the financial market.
14. The share of the non-Qatari investor in the profits of investment funds whose units are listed for trading on financial markets.
15. The share of the non-Qatari investor in profits resulting from the trading of all securities, including investment fund units, listed for trading on financial markets. The Regulation shall specify the conditions and controls for exempting the incomes stipulated in this Article from tax.

Section Three Accounting Period Article (5) The accounting period for a taxpayer conducting an activity shall be the Tax Year. However, the taxpayer may, after obtaining the Authority's approval, adopt an accounting period different from the Tax Year, in accordance with what the Regulation specifies.

Article (6) The taxpayer shall determine his Taxable Income based on accrual accounting principles used in commercial accounting, in accordance with International Accounting Standards, subject to the provisions of this Law and the Regulation. The taxpayer shall not use other accounting methods except after obtaining the Authority's approval.

Chapter Three Calculation of Tax Section One Taxable Income Article (7) Taxable Income shall be determined based on the Total Income arising from all transactions carried out by the taxpayer, after deducting allowable deductions and losses stipulated in this Article. Allowable deductions are defined as expenses and costs borne by the taxpayer, which meet the following conditions:

1. They are necessary to achieve Total Income.
2. They have been actually borne and supported by documents.
3. They do not increase the value of fixed assets used in the activity.
4. They relate to the Tax Year. The taxpayer may deduct losses incurred during the Tax Year from the Net Income of subsequent years. All of the above shall be as specified by the Regulation.

Article (8) The following expenses and costs shall not be deductible:

1. Expenses and costs incurred to achieve income exempt from tax.
2. Amounts paid in violation of State laws.
3. Fines and penalties imposed for violating State laws.
4. Expenses or losses related to compensation that was recovered or is recoverable, if such compensation was not included in the taxpayer's Total Income.
5. The share of total expenses spent on entertainment, hospitality, restaurant meals, vacations, club memberships, and client gifts, in accordance with the circumstances, conditions, and percentages specified by the Regulation.
6. Salaries, wages, bonuses, and anything similar, including in-kind benefits, paid to the owner, his spouse, and children, and to partners in a general partnership or limited partnership, and to members of the board of directors, and to the manager of a limited liability company who owns, directly or indirectly, the majority of shares in the company.
7. The branch's share of administrative and general expenses of the headquarters or main office that exceeds the percentage specified by the Regulation.
8. Commissions of foreign company agents that exceed the percentages specified by the Regulation.
9. Any other deductions not permitted, in accordance with the provisions of this Law or the Regulation.

Section Two Tax Rate Article (9) The tax rate shall be (10%) ten percent of the taxpayer's Taxable Income during the Tax Year. As an exception to the preceding paragraph, the tax rate shall be as follows:

1. The tax rate and all other tax conditions stipulated in agreements related to petrochemical industries, as well as those related to petroleum operations as defined by Law No. (3) of 2007 concerning the exploitation of natural wealth and its resources, shall apply, provided that the tax rate in all cases shall not be less than (35%) thirty-five percent.
2. Subject to the provisions of tax treaties, a final withholding tax of (5%) five percent of the total amount shall be imposed on royalties, interest, commissions, and payment for services performed wholly or partially in the State, paid to non-residents for activities not related to a permanent establishment in the State, as specified by the Regulation.
3. The tax rate stipulated in agreements in which the Government, ministries, other government agencies, bodies, public institutions, or persons representing the Government are parties, and which were concluded before the application of this Law, shall apply. If the agreement does not specify the tax rate, the tax shall be imposed at a rate of (35%) thirty-five percent.

Chapter Four Tax Obligations Section One Registration and Notification Article (10) Every taxpayer conducting an activity or achieving taxable income is obligated to:

1. Register with the Authority.
2. Notify the Authority of any change that may affect his tax obligations.
3. Submit a request to the Authority to obtain a unique tax number. The Regulation shall specify the conditions, controls, deadlines, and procedures necessary for this.

Section Two Submission of Tax Returns Article (11) The taxpayer, even if he is a beneficiary of a tax exemption, is obligated to submit a return to the Authority on the form prepared for this purpose, stating the Taxable Income and the amount of tax due. Subject to the provisions regarding tax assessment, financial penalties, and statute of limitations stipulated in this Law and the Regulation, the taxpayer may, with the Authority's approval, submit an amended return to correct errors contained in the return related to a previous tax year or to add omissions. The Regulation shall specify the conditions, controls, and procedures necessary for this.

Section Three Accounting Obligations Article (12) The taxpayer conducting an activity in the State is obligated to keep accounting books, records, and documents, in accordance with State laws and International Accounting Standards, and to retain them. The Authority may exempt some taxpayers from retaining them. This shall be according to the cases, conditions, and circumstances specified by the Regulation.

Article (13) Government agencies, companies, associations, private charitable associations, private institutions of public benefit, sole proprietorships, and any other entity specified by the Regulation are obligated to notify the Authority of contracts, agreements, and deals they conclude, within the limits and deadlines specified by the Regulation. Subject to regional and international tax treaties to which the State is a party, the entities stipulated in the preceding paragraph must provide the Authority, upon request, with any information relevant to tax purposes.

Chapter Five Authority's Powers and Duties Section One Tax Assessment Article (14) Tax shall be assessed based on the Taxable Income stated in the return, and the return shall be considered an assessment of tax and an obligation to pay it on the day of its submission. The Authority may amend the assessment based on the data contained in the return and supporting documents, in accordance with the provisions of this Law and the Regulation. The Authority may also make an estimated assessment based on any available data in case the taxpayer fails to submit his tax return or fails to provide the data and documents supporting the return. In the two cases stipulated in the preceding paragraphs, the Authority must notify the taxpayer of the elements of tax assessment and its value on the form prepared for this purpose, via a registered letter or any means indicating knowledge. The liquidator shall be considered a taxpayer, and assessment procedures shall be taken against him, in accordance with the conditions and controls specified by the Regulation.

Article (15) Subject to the provisions of the statute of limitations stipulated in this Law, the Authority shall not re-assess the tax due from the taxpayer for a tax year for which tax was previously assessed, unless new information comes to the Authority's attention that affects the taxpayer's tax obligations and was not considered in the previous assessment. The rules applicable to the initial tax assessment decision shall apply to the decision to re-assess the tax.

Section Two Obligation of Confidentiality Article (16) Authority employees must maintain the confidentiality of information and documents that come to their knowledge or are in their possession during or in connection with the performance of their duties. Authority employees are exempt from this obligation when disclosing such information and documents in the following cases:

1. To the taxpayer or his agent, or to any government agency, provided the taxpayer agrees, unless the disclosure is prohibited by a provision in another law or an international or regional agreement to which the State is a party.
2. Upon request by any judicial authority.
3. In the framework of information exchange procedures under an international or regional tax treaty to which the State is a party.

Chapter Six Objections and Appeals Section One Objections Article (17) The taxpayer may object, via a registered letter or any means indicating knowledge, to the tax assessment decision within thirty days from the date of notification thereof. The objection shall be submitted to the Authority, and its submission shall suspend the execution of the tax assessment decision. If the taxpayer does not submit an objection within the period stipulated in the first paragraph of this Article, the tax assessment decision shall become final, and the tax shall be due and payable.

Article (18) The Authority shall review the objection and notify the taxpayer or the Responsible Person of its decision, by any means indicating knowledge, within sixty days from the date of submission of the objection. The passage of sixty days without a response to the objection shall be considered a rejection thereof. If the taxpayer agrees with the Authority's decision issued on the objection submitted by him, the tax shall be assessed finally based on that.

Section Two Appeals Article (19) One or more committees named "Tax Disputes Committee" shall be established within the Authority, presided over by a judge of the Court of Appeal chosen by the Supreme Council of the Judiciary. The formation of the Committee, the organization of its work, the appeal procedures before it, and the determination of its remuneration shall be issued by a decision of the Council of Ministers, upon the proposal of the Minister. The appointment of the Chairman and members of the Committee shall be issued by a decision of the Minister. The Committee shall have jurisdiction to rule on requests submitted by the taxpayer appealing the Authority's decisions, and any other jurisdictions specified by the decision organizing its work. The Committee may reduce the financial penalties stipulated in this Law. The Committee is obliged to observe the general principles and procedures of litigation. The taxpayer and the Authority may appeal the Committee's decision before the Appellate Administrative Circuit within sixty days from the date of notification of the decision. Appealing the decision shall not suspend the execution of the Committee's decision, unless the court decides otherwise.

Chapter Seven Collection and Refund of Tax Section One Collection of Tax Article (20) The taxpayer shall pay the tax due based on his submitted return, on the same day of submitting the return. In the event of notification of the Authority's decision on assessment by amendment or estimation, and the expiration of the objection period stipulated in Article (17) of this Law without submitting an objection, the taxpayer is obligated to pay the tax and related financial penalties within thirty days from the date of expiration of the mentioned period. In the event of the taxpayer's agreement with the Authority's decision issued on the objection, the due tax shall be paid within thirty days from the date of notification of this decision. In cases other than those stipulated in the preceding two paragraphs, the tax and related financial penalties shall be collected in a lump sum within thirty days from the date of expiration of the period stipulated in Article (18) of this Law without response, or from the date of notifying the taxpayer or the Responsible Person of the Authority's response to the objection. The Authority may, upon the request of the interested party, approve the payment of the tax and related financial penalties in installments, as specified by the Regulation. If the taxpayer fails to pay any installment at the specified time, all remaining installments shall become due immediately. The assignor and assignee, and the seller and buyer, shall be jointly and severally liable for the payment of taxes and financial penalties due for the assigned or sold activity until the date of notifying the Authority of the documented assignment or sale.

Section Two Seizure of Taxpayer's Assets Article (21) In cases where it appears that the collection of tax is threatened with loss, the President may issue an order from the Summary Matters Judge to impose a precautionary seizure on the taxpayer's assets necessary for the collection of tax and related financial penalties, whether in the possession of the taxpayer or others. These assets shall be considered seized precautionarily from the date of notifying the taxpayer of the Summary Matters Judge's order, and the taxpayer shall not dispose of them except in the case of lifting the precautionary seizure by order of the Summary Matters Judge. The taxpayer and interested parties may appeal the order to impose precautionary seizure before the competent court within thirty days from the date of notification.

Article (22) If the tax assessment decision and related financial penalties become final and are not paid on the specified date, the President shall take execution seizure measures on the taxpayer's assets necessary for the collection of tax, whether these assets are in the possession of the taxpayer or others. The Authority may request, via a registered letter, any person to submit to it, within thirty days from the date of receiving the letter, a declaration of amounts owed to the taxpayer on his behalf. The declaration shall include the following: a. Amounts owed to the taxpayer and their payment deadlines. b. Amounts in his possession due to the taxpayer before a third party, and whether he is authorized to pay the taxpayer on behalf of the third party. The person mentioned in the preceding paragraph shall pay the amounts due to the taxpayer to the Authority within the limit of the tax and related financial penalties within thirty days from the date of their maturity. Amounts that have matured at the date of submitting the declaration to the Authority must be paid within thirty days from this date. In the event of failure to submit the declaration by this person within the specified period, or in the event of failure to pay the amounts to the Authority in accordance with the preceding paragraph, the Authority shall take execution seizure measures on this person's assets. To apply the provisions of the first and fourth paragraphs of this Article, the Authority shall notify the debtor, and the seizure shall be executed by the Authority in accordance with the law. The provisions of the second, third, and fourth paragraphs of this Article shall not apply to banks, except by order of the court.

Section Three Refund of Tax and Financial Penalties Collected Without Just Cause Article (23) Subject to the provisions of the statute of limitations stipulated in this Law, the taxpayer may recover amounts of tax and financial penalties collected from him without just cause, by a request submitted to the Authority. The Authority shall notify the taxpayer of its decision regarding the refund request within sixty days from the date of its submission. The taxpayer may appeal to the Tax Disputes Committee in the event of the Authority's rejection of the refund request, or in the event of the Authority failing to notify the taxpayer of its decision within the mentioned period. In the event of the Authority's delay in returning the amounts collected without just cause within the mentioned period, the taxpayer shall have the right to compensation, calculated in accordance with the provisions of the Regulation.

Chapter Eight Financial Penalties and Sanctions Section One Financial Penalties Article (24) Except for acts constituting a crime under the provisions of Article (26) of this Law, the President or his delegate shall impose the financial penalty specified in each of the following items in the cases stipulated therein:

1. Every taxpayer who fails to submit the return within the periods prescribed by this Law and the Regulation shall be imposed a financial penalty of (500) five hundred Riyals for each day of delay, with a maximum of (180,000) one hundred and eighty thousand Riyals.
2. Every taxpayer who fails to pay the tax within the periods prescribed by this Law and the Regulation, and every natural or legal person who fails to remit the withheld tax amount at the specified times, shall be imposed a financial penalty of (2%) two percent of the amount of tax due for each month of delay or part thereof, not exceeding the amount of tax due.
3. Every taxpayer who violates the provisions of registration and notification stipulated in this Law and the Regulation shall be imposed a financial penalty of (20,000) twenty thousand Riyals.
4. Every taxpayer benefiting from a tax exemption who fails to submit the tax return and documents to be attached thereto in accordance with the provisions of this Law and the Regulation shall be imposed a financial penalty of (10,000) ten thousand Riyals.
5. Every taxpayer who violates the provisions of submitting audited final accounts, keeping accounting books, and retaining them stipulated in this Law and the Regulation shall be imposed a financial penalty of (30,000) thirty thousand Riyals.
6. Except for government agencies, every entity that fails to notify the Authority of contracts, agreements, and deals it concludes in accordance with the provision of Article (13) of this Law shall be imposed a financial penalty of (10,000) ten thousand Riyals.
7. Every person who fails to withhold tax at source in accordance with the provision of Article (9) of this Law shall be imposed a financial penalty equivalent to the amount of tax not withheld, in addition to paying the due tax amount.
8. Every person who violates the provisions of decisions issued in accordance with the second paragraph of Article (34) of this Law shall be imposed a financial penalty not exceeding (500,000) five hundred thousand Riyals. In applying the provisions of items (1) and (2) of this Article, the delay period shall start from the day following the expiration of the last deadline for submitting the return and end on the date of submitting the return or paying the tax, as the case may be. The interested party shall be notified of the financial penalties imposed, as specified by the Regulation.

Article (25) The President or his delegate, within the limit of (500,000) five hundred thousand Riyals, and the Minister for amounts exceeding that, may exempt the taxpayer, wholly or partially, from the financial penalties stipulated in the preceding Article, in the event that the taxpayer submits justifications accepted by the Authority. The exemption stipulated in this Article shall be repealed if the taxpayer submits an appeal in accordance with the provisions of Article (19) of this Law.

Section Two Sanctions Article (26) Without prejudice to any harsher penalty stipulated in another law, every taxpayer or responsible person who:

1. Submitted forged or copied books, records, or documents.
2. Used fraudulent methods, including submitting forged, copied, or incorrect data or documents, with the intent to obtain a tax deduction or exemption or to recover tax previously paid.
3. Intentionally failed to register for tax purposes or concealed real income or any taxable activity.
4. Committed any act with the intent to prevent Authority employees from performing their duties. Shall be punished with imprisonment for a period not exceeding one year and a fine not exceeding three times the tax due, or with one of these two penalties.

Article (27) The person who intentionally participated in violating any of the obligations stipulated in this Law shall be jointly and severally liable with the taxpayer or the responsible person for paying any amounts due as a result of the violation. The assignor and assignee, partners in personal companies, and the representative of the non-resident person and his principal shall be jointly and severally liable for paying taxes and financial penalties due to the Authority, in accordance with the controls specified by the Authority.

Article (28) Without prejudice to any harsher penalty stipulated in another law, every person who violates the provisions of Article (16) of this Law shall be punished with imprisonment for a period not exceeding six months and a fine not exceeding (50,000) fifty thousand Riyals, or with one of these two penalties.

Article (29) Penalties stipulated in this Law shall be doubled in case of recidivism. An accused is considered a recidivist if they commit a similar crime within five years from the date of completion of the execution of the sentenced penalty or its lapse due to the passage of time.

Article (30) Criminal proceedings regarding the crimes stipulated in Articles (26) and (27) of this Law shall not be initiated except upon a written request from the President.

Article (31) The President or their delegate may settle the crimes stipulated in Articles (26) and (27) of this Law, before initiating criminal proceedings or during their consideration and before a final judgment is rendered, in exchange for paying half the maximum prescribed penalty, the due tax, and financial penalties. Settlement results in the prohibition of initiating criminal proceedings or their extinction, as applicable. The Public Prosecution shall order the suspension of penalty execution if settlement occurs during its execution.

Article (32) Employees of the Authority who are issued a decision granting them the status of judicial police officers, by the Public Prosecutor in agreement with the Minister, shall have the power to seize and document violations of the provisions of this Law and the executive decisions thereto. These employees have the right to enter the premises where the taxpayer conducts their activity and its annexes, to perform any acts required for the application of the provisions of this Law, in accordance with what is specified in the Executive Regulations.

Chapter Nine General Provisions

Article (33) In the event that a taxpayer enters into agreements, operations, or transactions where one of their primary objectives is to avoid paying the due tax, the Authority may withdraw the tax benefit obtained as a result of these agreements, operations, or transactions, in accordance with the provisions of the Executive Regulations. The Authority may, in any of the cases stipulated in the preceding paragraph, take all or some of the following measures:

1. Apply the market price value, in the case of full competition, to a disposition or economic event that the taxpayer has subjected to a different value.
2. Recharacterize the disposition if its form does not reflect its true substance.
3. Modify the amount of tax due from the taxpayer or any other person who has a relationship with the agreements or transactions stipulated in the first paragraph of this Article.

Article (34) The application of this Law shall not prejudice any obligations imposed by international agreements or arrangements to which the State is a party, in the field of information exchange for tax purposes or combating international tax avoidance. The Minister shall issue the necessary decisions to enforce these obligations, and their decisions in this regard shall be binding on all entities and entities in the State, including bodies that apply special tax systems under the laws governing them.

Article (35) Tax exemptions stipulated in this Law may be amended by a decision of the Council of Ministers, upon the proposal of the Minister.

Article (36) The Minister shall issue, upon the proposal of the President, a decision regarding the controls and provisions for the procedures of granting or canceling tax exemptions. An exemption decision shall be issued by the Minister if the duration of the exemption does not exceed five years, and by the Council of Ministers if it exceeds that. The Council of Ministers may, upon the proposal of the Minister, determine a preferential tax rate for certain sectors or projects due to their nature or the nature of the region in which they are established.

Article (37) The Authority's right to assess tax and the financial penalties related to it for a specific tax year shall expire upon the lapse of five years following the year in which the taxpayer submitted the declaration. In the event that the taxpayer fails to submit the declaration, the Authority's right to assess tax shall expire upon the lapse of ten years following the tax year for which the declaration was not submitted. In the event that the taxpayer fails to register with the Authority in accordance with the provisions of Article (10) of this Law, the period stipulated in the preceding paragraph shall start from the date of the Authority's discovery of the taxpayer's activities. In addition to the causes of interruption of limitation periods prescribed by law, the periods mentioned in the preceding paragraphs shall be interrupted by the taxpayer's notification via registered letter of any of the following matters: a. A tax assessment decision in accordance with the provisions of Articles (14) and (15) of this Law. b. Payment of the due tax or financial penalties. c. Referral of the dispute to the Tax Appeal Committee.

Article (38) The Authority's right to collect taxes and financial penalties shall lapse upon the passage of ten years following the year in which the amount of tax and financial penalties became due.

Article (39) The taxpayer's right to request the refund of taxes and financial penalties collected from them without justification shall lapse upon the passage of five years from the date of proof that the Authority had no right to collect the amount of tax and financial penalties related to it and their knowledge thereof. In addition to the causes of interruption of limitation periods prescribed by law, the period mentioned in the preceding paragraph shall be interrupted by the request that the taxpayer notifies the Authority, demanding the return of taxes and financial penalties collected from them without justification.