Qatar has taken a significant step in adopting the OECD Pillar Two framework. We set out below what this means for multinational enterprise groups with a presence in Qatar, including through QFC-licensed entities.
15% – Minimum effective tax rate
€750M Consolidated revenue threshold
Effective from 1 Jan 2025
Legislative background. Council of Ministers Resolution No. 2 of 2026, published on 12 February 2026, introduced the implementing rules for Qatar’s Global and Domestic Minimum Tax under Law No. 22 of 2024. The legislation aligns Qatar with the OECD’s GloBE Rules and applies to fiscal years beginning on or after 1 January 2025.
Scope. The rules apply to MNE groups with consolidated group revenues of at least EUR 750 million in at least two of the previous four fiscal years. All in-scope QFC-licensed entities will be captured.
KEY COMPONENTS
| DMTT | Domestic Minimum Top-up Tax: ensures Qatar collects top-up tax locally before it can be collected by another jurisdiction |
| b1 Jan 20251 Jan 2025 | Income Inclusion Rule: allows a parent entity’s jurisdiction to impose top-up tax where a subsidiary is undertaxed |
COMPLIANCE OBLIGATIONS
| Registration | In-scope entities will be required to register with the relevant authority |
| Notification | Notification obligations apply; details are being finalised by QFC in coordination with the GTA |
| Return filing | Returns for FY 2025 are expected to be filed by 30 June 2027 |
What should you do now?
MNE groups with QFC-licensed entities should assess their exposure to the Global and Domestic Minimum Tax as a matter of priority. This includes reviewing group revenue thresholds, effective tax rates across jurisdictions, and readiness for registration and filing obligations.
If you would like to discuss how this legislation may affect your group or require assistance with a GMT exposure assessment, please do not hesitate to contact our Qatar team.