DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar
The DTA allows full relief from UK tax on interest beneficially owned by
* Individuals * Pension schemes * The state of Qatar, one of its political subdivisions or local authorities or statutory bodies * Companies, provided that they meet one of the conditions set out in Article 11(3)(a) * Financial institutions described at Article 11(3)(a)(vi)
or where the interest is paid by one of the payers set out in Article 11(3)(b)
Relief may be restricted, where there is a “special relationship” between the lender and borrower, on the amount of interest which exceeds that appropriate to arms-length terms. There is also a general anti-abuse provision at Article 11(7).