There is no concept of group taxation for Qatar tax purposes.
Anti-avoidance provisions apply to related-party transactions. In determining the arm's-length value, the unrelated comparable price method should be used (i.e. the price of services or goods that would have been applied should the transaction be between unrelated parties). It is possible to make an application to the General Tax Authority to use another method approved by the Organisation for Economic Co-operation and Development (OECD).
There are no specific thin capitalisation rules in Qatar, although consideration should be given to the anti-avoidance provision noted above.
Controlled foreign companies (CFCs)
There are no CFC provisions in Qatar.