Executive summary

The Qatar General Tax Authority (GTA) has announced the launch of the global and domestic minimum tax (Pillar Two) registration and notification service through the Dhareeba platform, marking the commencement of the Pillar Two compliance process for in-scope multinational enterprise groups (MNE Groups) operating in Qatar. The announcement requires affected groups to complete initial registration and notification procedures through the newly activated functionality on the Dhareeba portal.

The GTA has clarified that, for fiscal years beginning in 2025, the MNE Group must appoint a Designated Local Entity (DLE), which will then be responsible for completing the registration and notification process within three months from the date on which the authority announced the launch of the registration service. Based on the activation of the service on 2 August 2026, the initial registration and notification deadline is expected to fall on 2 November 2026.

This development follows Qatar's implementation of the amendments to the Law No. 22 of 2024 and Resolution of the Council of Ministers No. 2 of 2026 — referred to as the Law and the Resolution, respectively — which collectively constitute the Qatar Pillar Two Framework. This framework introduced Domestic Minimum Top-Up Tax (DMTT) and Income Inclusion Rule (IIR) as part of the country's adoption of the Organisation for Economic Co-operation and Development/Group of 20 (OECD/G20) Inclusive Framework Pillar Two rules. The rules apply to MNE Groups with consolidated annual revenues of at least €750m in at least two of the four preceding fiscal years and are effective for fiscal years beginning on or after 1 January 2025.

Detailed discussion

Scope of the registration requirement

Under Qatar's Pillar Two Framework, group-based registration is mandatory for in-scope MNE Groups and qualifying joint venture groups (JV Groups) that meet the relevant scope requirements. Registration must be completed through the Dhareeba platform. The requirement applies regardless of whether a group ultimately expects to incur DMTT or IIR liability.

The registration obligation extends to constituent entities established in Qatar, including entities operating in the Qatar Financial Centre, Qatar Free Zones Authority, Qatar Science & Technology Park and Qatar Media City, provided they form part of an in-scope MNE Group. Qualifying JV Groups must register independently from the main MNE Group.

DLE requirements

As part of the registration process, in-scope MNE groups and qualifying JV Groups should appoint a DLE to act on their behalf to meet Pillar Two obligations in Qatar. The DLE is responsible for:

• Registering initially for Pillar Two
• Renewing registration annually
• Submitting a Global Anti-Base Erosion (GloBE) Information Return (GIR) notification and filing the GIR
• Filing DMTT returns
• Filing IIR returns
• Paying associated DMTT and IIT top-up tax liabilities
• Maintaining records and information
• Responding to communications from the GTA

There are two scenarios for DLE appointment, as follows:

1. If the Ultimate Parent Entity (UPE) is located in Qatar, the UPE will generally be treated as the DLE unless another domestic constituent entity is formally appointed.
2. If the UPE is located outside Qatar, a domestic constituent entity must be appointed as the DLE.

MNE Groups must submit an Appointment Declaration through Dhareeba to confirm the appointment of the DLE.

DLEs of JV Groups are separately appointed.

Penalties and enforcement

The Qatar Pillar Two Framework includes a range of administrative penalties for noncompliance. Key penalties include:

• Failure to register for Pillar Two: 20,000 Qatari riyal (QAR20,000)
• Late filing of DMTT returns: QAR500 per day, capped at QAR180,000
• Late filing of IIR returns: QAR500 per day, capped at QAR180,000
• Late payment of DMTT or IIR liabilities: 2% of the unpaid tax per month (or part thereof), capped at the total tax due
• Failure to comply with GIR notification requirements: QAR20,000

Additional penalties may also apply for broader compliance failures, including:

• Failure to maintain required books and records: QAR30,000
• Failure to provide information or documents requested by the GTA: QAR200 per missing document, capped at QAR72,000
• Providing incomplete or incorrect information affecting tax calculations: QAR100 per incorrect item, capped at QAR10,000, together with 50% of any unpaid tax resulting from the incorrect information

The GTA may also initiate an enforced registration process if an in-scope group fails to register voluntarily.

Transitional relief measures

Article 4 of Law No. 22 states that transitional penalty relief may be available during the transition period, defined as any fiscal year beginning on or before 31 December 2027, provided the fiscal year does not end after 30 June 2029. During this period, general penalties may be waived if an MNE Group can demonstrate that it took reasonable measures to comply with the Qatar Pillar Two Framework. However, the relief does not apply in cases involving tax evasion, fraud, deliberate misrepresentation or intentional noncompliance. These measures are intended to facilitate a smoother transition to the new regime while encouraging good-faith compliance efforts.

Implications

The activation of the Pillar Two registration and notification functionality represents a significant milestone in the practical implementation of Qatar's Pillar Two framework. Registration marks the beginning of the broader compliance process for affected MNE Groups and JV Groups.

MNE Groups with operations in Qatar should review whether they are within the scope of the Pillar Two rules, identify all relevant Qatar constituent entities, joint ventures and joint venture subsidiaries. Businesses should also begin gathering the information required for registration, notification and future filing obligations.

Given the relatively short period available for initial registration for fiscal years beginning in 2025 and the potentially significant penalties for noncompliance, affected groups should establish appropriate governance procedures, allocate responsibilities among tax and finance teams, and monitor further GTA guidance and announcements. Early preparation will help organizations comply with the initial registration and notification requirements and support ongoing Pillar Two reporting and compliance obligations in Qatar.