Details of the Algeria - Qatar Income Tax Agreement (2008) [Arabic text], signed on 3 July 2008, have become available. The treaty was concluded only in the Arabic language. The treaty generally follows the OECD Model (2008).
Taxes covered by the treaty include, in the case of Algeria, the royalty, the oil income tax and the annual tax on income with respect to activities of research, exploitation and transportation by pipeline of hydrocarbons.
The maximum rates of withholding tax are:
|-||0% on dividends;|
|-||0% on interest; and|
|-||5% on royalties.|
Deviations from the OECD Model (2008) include that:
|-||the term "resident" means in the case of Qatar any individual who has a permanent home, his centre of vital interest, or habitual abode in Qatar, and a company incorporated or having its place of effective management in Qatar (article 4);|
|-||the definition of permanent establishment contains:
|-||the definition of royalties in article 12 includes payments for tapes used for radio or television broadcasting;|
|-||there is no provision with respect to capital gains on the disposal of shares in real estate companies similar to article 13(4) of the OECD Model (2008);|
|-||the treaty contains a provision on independent personal services similar to article 14 of the UN Model (2001);|
|-||article 16 provides that directors fees and others similar payments are taxable only in the state of residence of the company paying the fees; and|
|-||the treaty includes a provision (article 20) on professors and researchers.|
In general, the credit method is used to avoid double taxation. Both states provide for a tax sparing credit.
The treaty entered into force on 16 March 2011. It applies from 1 January 2012.
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