Executive summary

On 15 March 2026, the State of Qatar published Council of Ministers' Decision No. (4) of 2026 (the Decision) in the Official Gazette, amending the Executive Regulations of Income Tax Law No. (24) of 2018, as amended, issued by Council of Ministers' Decision No. (39) of 2019.

The Decision introduces the Trusted Entity concept for qualifying Qatar taxpayers, together with the Trusted Entity Service, which enables the direct application of withholding tax (WHT) benefits under applicable Double Taxation Avoidance Agreements or Double Tax Treaties (DTTs), provided the taxpayer meets the qualifying criteria, complies with the requisite processes and secures the approval of the General Tax Authority (GTA).

The Decision aims to align Qatar's WHT procedures with international best practices, enhance the ease of doing business and improve efficiency for cross-border transactions. It takes effect from 16 March 2026, which is the day following its publication in the Official Gazette.

In addition, the President of the General Tax Authority (GTA) is expected to issue a decision setting out the specific quantitative criteria required to apply for Trusted Entity status.

Detailed discussion

Background

The Qatar Income Tax Law No. (24) of 2018 provided that the application of WHT benefits under an applicable DTT historically operated under a pay-and-refund mechanism.

This approach required a Qatar taxpayer to withhold WHT at a rate of 5% at source on payments made to a nonresident supplier (Foreign Person) and remit it to the GTA. In situations in which a WHT benefit applied under a DTT concluded between Qatar and the country of tax residence of the Foreign Person, the Foreign Person could subsequently apply to the GTA for a WHT refund.

The Trusted Entity Service enables the direct application of DTT WHT benefits at source, thereby reducing or eliminating the 5% WHT rate if the relevant conditions are satisfied.

Key provisions under the Decision

Trusted Entity concept

A Qatar taxpayer seeking registration as a Trusted Entity with the GTA, should submit an application using the prescribed form, together with the required supporting documentation.

Eligibility criteria

To qualify as a Trusted Entity, an applicant should:

• Be registered with the GTA
• Complete a questionnaire addressing administrative capacity, human resources and technology capabilities required to meet the obligations of a Trusted Entity
• Meet at least one of the quantitative thresholds for the Trusted Entity status, based on either:
• The number of transactions subject to WHT at source declared to the GTA in the tax year preceding the year of application
• The total amount of WHT withheld at source in the tax year preceding the year of application

Validity period

The Trusted Entity status is valid for a period of three years from the date of approval by the GTA.

Renewal

A taxpayer can renew the Trusted Entity status by submitting a renewal application to the GTA at least 60 days prior to the expiry of the existing Trusted Entity status.

Benefits

Once registered as a Trusted Entity, a Qatar taxpayer may make payments to an approved Foreign Person applying the applicable WHT rate in the DTT between Qatar and the jurisdiction of tax residence of the Foreign Person.

Foreign Person

A Foreign Person seeking to benefit from the direct application of a DTT, from a WHT perspective, should submit an application to a Trusted Entity using the form prescribed by the GTA, together with supporting documentation, such as a tax residency certificate, among others.

The Foreign Person must make certain declarations in the application to the Trusted Entity, including confirmation of:

• Its country of tax residence under a DTT concluded with Qatar
• Its status as the beneficial owner of the income derived from Qatar
• The specific DTT articles under which WHT benefits are claimed
• The transactions not being undertaken primarily to obtain DTT benefits
• The income not being attributable to a permanent establishment registered in Qatar

The Trusted Entity must decide on the Foreign Person's application within 60 days of submission.

Reporting of transactions to the GTA

A Trusted Entity should report to the GTA all WHT transactions benefiting from the direct application of a DTT, while applying WHT as usual to payments that do not benefit from the direct application of a DTT.

Failure to comply with the reporting requirements will result in financial penalties under the provisions of Income Tax Law No. (24) of 2018.

Implications

The Decision represents a significant change to Qatar's WHT framework and introduces benefits for direct DTT application. It also imposes additional compliance and documentation requirements for Qatar taxpayers whose Trusted Entity status is approved.

Qatar taxpayers making cross-border payments to Foreign Persons should assess their eligibility for Trusted Entity status and consider the potential benefits, including reduced administrative burden in applying DTT benefits, smoother contract negotiations with Foreign Persons and improved cash-flow outcomes for nonresident income recipients.