16 February 2026 Qatar issues resolution on rules to apply global and domestic minimum taxes
The Resolution of the Council of Ministers No. 2 of 2026 (2026 Regulations Amendment), published in the Official Gazette on 12 February 2026, provides rules for applying the Global and Domestic Minimum Taxes introduced through Law No. 22 of 2024 (2024 Law Amendment). The 2024 Law Amendment amended provisions of Income Tax Law No. (24) of 2018 (as amended by Law No. (11) of 2022) (ITL). (This Alert refers to the 2026 Regulations Amendment and the 2024 Law Amendment together as the Qatar Global Anti-Base Erosion (GloBE) Legislation.) Unlike the full ITL, the Qatar GloBE Legislation applies to all areas of Qatar, including to entities licensed by the Qatar Financial Centre, the Qatar Free Zones Authority, Qatar Science & Technology Park and Qatar Media City. The Qatar GloBE Legislation introduces a Domestic Minimum Top-up Tax (DMTT) to ensure that in-scope multinational enterprise groups (MNE Groups) operating in Qatar generally pay a minimum effective tax of 15% on their excess profits, as intended in the GloBE Model Rules (GloBE Rules). The Qatar GloBE Legislation also introduces an Income Inclusion Rule (IIR) under which a Parent Entity located in Qatar is required to compute and pay Top-up Tax (TUT) based on its ownership interest in a low-taxed foreign Constituent Entity (CE) or GloBE joint venture (JV). The Qatar GloBE Legislation is effective from 1 January 2025 and applies to fiscal years starting on or after 1 January 2025. It applies to MNEs operating in Qatar with a consolidated annual revenue of €750m or more in at least two of the previous four fiscal years. The Qatar GloBE Legislation should be interpreted consistently with the Commentary to the GloBE Rules (Commentary) and any Administrative Guidance, including the agreed rule order and applicable safe harbors. Further, any amendments to the Commentary, including through Agreed Administrative Guidance, shall apply to the interpretation of the Qatar GloBE Legislation for fiscal years beginning after the date the amendment is approved by the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Inclusive Framework, unless a Decision of the Council of Ministers specifically deems the amendments inapplicable. An exception to this position will apply if the amendment to the Commentary or Administrative Guidance refers to an earlier effective date, in which case that earlier effective date will prevail. The Qatar GloBE Legislation incorporates financial penalties for noncompliance that are in line with previously stated financial penalties in the ITL, including providing for a "transitional penalty relief regime." Other penalties are also outlined that are not covered by the transitional penalty relief regime. The Qatar GloBE Legislation closely follows the GloBE Rules, including legislating rules meeting the requirements of a Qualified Domestic Top-up tax (QDMTT) and QDMTT Safe Harbour. These rules include a mandatory variation related to allocation of cross-border taxes indicated in paragraphs 118.28 to 118.30 of the QDMTT Commentary. However, Qatar has not adopted any of the optional provisions indicated in the QDMTT Safe Harbour Commentary. On 5 January 2026, Qatar was added to the OECD's Central Record, which recognized Qatar as a jurisdiction with a QDMTT Safe Harbour and a Qualified IIR, effective from 1 January 2025.
The Qatar GloBE Legislation represents Qatar's commitment to the OECD/G20 Inclusive Framework on the BEPS 2.0 project and marks a significant milestone as Qatar joins other Gulf Cooperation Council countries to legislate provisions from the GloBE Rules. The DMTT rules allows Qatar to retain the right to tax Qatar-sourced income and to prevent foreign governments' collection of tax on Qatari-sourced income. Further, the IIR allows Qatari-headquartered MNE Groups and other Qatar parent entities the right to tax the low-taxed excess profits of their foreign CEs or JVs. The IIR also protects in-scope Qatari-headquartered companies from being subject to the Undertaxed Profits Rule (UTPR) on their non-Qatar, low-taxed CEs. An MNE Group is defined, in Article 1.2 of the GloBE Rules, as a group that includes at least one CE that is not located in the jurisdiction of the UPE. A CE is defined under Article 1.3 of the GloBE Rules. The Qatar GloBE Legislation applies to MNE Groups operating in Qatar, with revenues of €750m or more based on the UPE's Consolidated Financial Statements for at least two of the four fiscal years immediately preceding the tested year. The Qatar GloBE Legislation introduces a DMTT, which is defined as a tax calculated on the basis of domestic excess profits of local CEs and JVs, in a manner consistent with the GloBE Rules. Further, the Qatar GloBE Legislation includes an IIR, as defined in Article 2.1 of the GloBE Rules, under which a Parent Entity located in Qatar is required to compute and pay TUT based on its ownership interest in a low-taxed foreign CE or JV. The DMTT and the IIR will be interpreted and applied in conformity with the GloBE Rules. All in-scope CEs, including JVs and JV subsidiaries operating in the state, should register with the GTA through the designated electronic platform. The President of the GTA shall, by a decision, designate the electronic platform to be used for the registration and ongoing compliance as well as the specific information required for registration and due date. Under Article 12.1.1, a DLE shall be appointed to fulfill the registration obligation. The President of the GTA shall issue a decision prescribing the manner and form by which that Entity is designated. Additionally, Article 2.4.5 requires the DLE to fulfill the DMTT filing and payment obligations. Each domestic CE is jointly and severally liable to pay a DMTT for each fiscal year of the MNE Group that includes the domestic CE. The DMTT shall equal the amount of the TUT determined for all domestic CEs of the MNE Group. Each domestic JV and its domestic JV subsidiaries are also jointly and severally liable to pay a DMTT for each fiscal year of the MNE Group that includes the domestic JV or domestic JV subsidiary; however, the DMTT for the fiscal year shall equal the TUT for the domestic JV Group, which is calculated separately. The Qatar GloBE Legislation does not address the method that should be used to allocate the DMTT to each domestic CE and JV subsidiary. Qatari CEs, or a DLE on their behalf, should file a GIR in accordance with Article 8.1.1 of the GloBE Rules. In addition, in case of central filing outside Qatar, the DLE should notify the GTA regarding the filing location of the GIR, in accordance with Article 8.1.3 of the GloBE Rules. As per Article 8.1.6, the due date of the GIR or the GIR notification, as applicable, will be 15 months after the last day of the reporting fiscal year subject to Article 9.4.1, which allows for filing 18 months after the last day of the reporting fiscal year, i.e., the first transition year of any CE of the MNE Group. Under Article 12.2, a DLE should also file a separate IIR and DMTT return within the same deadline as the GIR filing. Payment must be made by the same deadline as well; however, there is a placeholder in the Qatar GloBE Legislation allowing the President of the GTA to issue a decision for calculating, paying and administering the DMTT advance payments, including the deadlines for advance payments. The Qatar GloBE Legislation closely adheres to the GloBE Model Rules in determining GloBE Income or Loss, which shall rely on the Financial Accounting Net Income or Loss for a CE (before any consolidation adjustments eliminating intragroup transactions) in preparing the UPE's Consolidated Financial Statements. Under the Qatar GloBE Legislation, the calculation of the DMTT and IIR liability should be based on the financial accounting standard and presentation currency used in the preparation of the Consolidated Financial Statements of the UPE. Domestic JVs, domestic JV subsidiaries, stateless CEs (flow-through entities and permanent establishments) and Minority-Owned CEs are in scope of the Qatar GloBE Legislation and require separate ETR and TUT calculations under the GloBE Rules. They are also subject to separate filing requirements. Flow-through entities that are stateless CEs are in scope if they are created under the laws of the state. Permanent establishments that are stateless CEs are in scope if the place of business (or deemed place of business) is located in the state and, either, there is no tax treaty applicable or an applicable tax treaty grants taxing rights to the state. The Qatar GloBE Legislation includes a provision related to the exclusion from the DMTT for MNE Groups in their Initial Phase of International Activity. Under the Qatar GloBE Legislation, the Minister of Finance may issue a decision on reducing the DMTT TUT to zero, provided that none of the ownership interests of the CEs and stateless CEs located in the state are held by a Parent Entity subject to a Qualified Income Inclusion Rule of another jurisdiction. Qatar will consider other jurisdictions' qualifying status and safe harbor eligibility based on the outcomes of the transitional qualification mechanism and the full legislative review, along with ongoing monitoring, developed by the OECD BEPS Inclusive Framework and documented in the OECD's Central Record. MNEs operating in Qatar must evaluate the impact of the Qatar GloBE Legislation on their operations and facilitate compliance with the new requirements. Future regulatory updates are expected to offer more clarity on the compliance requirements.
Document ID: 2026-0441 | ||||||
