Qatar has taken a significant step in implementing the OECD/G20 Base Erosion and Profit Shifting (BEPS) 2.0 framework through the issuance of Resolution of the Council of Ministers No. 2 of 2026 (the 2026 Regulations Amendment). Published in the Official Gazette on 12 February 2026, the amendment introduces detailed rules for applying the Qatar Global Minimum Tax regime enacted under Law No. 22 of 2024.

Collectively, these measures form the Qatar Global Anti-Base Erosion (GloBE) Legislation and establish Qatar’s domestic framework for OECD Pillar Two compliance.

Unlike the broader Income Tax Law (ITL), the Qatar Global Minimum Tax rules apply uniformly across all jurisdictions in the country, including entities licensed by the Qatar Financial Centre (QFC), Qatar Free Zones Authority (QFZ), Qatar Science & Technology Park (QSTP), and Qatar Media City.

Domestic Minimum Top-up Tax (DMTT) and Income Inclusion Rule (IIR)

A central component of the legislation is the introduction of the Domestic Minimum Top-up Tax (DMTT), which ensures that in-scope multinational enterprise (MNE) groups pay a minimum effective tax rate of 15% on excess profits generated in Qatar.

In parallel, Qatar has enacted an Income Inclusion Rule (IIR), requiring Qatar-based parent entities to compute and remit top-up tax (TUT) on low-taxed profits of foreign subsidiaries or joint ventures. This strengthens Qatar’s alignment with the global minimum tax standards under Pillar Two.

The rules apply to MNE groups with consolidated annual revenues of €750 million or more in at least two of the preceding four fiscal years and are effective for fiscal years beginning on or after 1 January 2025.

The Qatar Global Minimum Tax legislation must be interpreted in accordance with the OECD GloBE Model Rules, related commentary, and future administrative guidance unless specifically excluded by the Council of Ministers.

OECD Recognition and Qualified Domestic Minimum Top-up Tax (QDMTT)

Qatar’s framework closely follows OECD requirements for a Qualified Domestic Minimum Top-up Tax (QDMTT) and a QDMTT Safe Harbour. Although the optional provisions within the Safe Harbour framework were not adopted, Qatar has aligned its domestic rules with international standards.

On 5 January 2026, Qatar was added to the OECD Central Record as a jurisdiction operating a QDMTT Safe Harbour and a Qualified IIR, both effective from 1 January 2025.

Financial penalties mirror those under the Income Tax Law and are supplemented by a transitional penalty relief regime.

Registration and Reporting Requirements Under Qatar Global Minimum Tax

Registration Obligations

• All in-scope constituent entities (CEs), including joint ventures and JV subsidiaries, must register with the General Tax Authority (GTA) via an electronic platform designated by GTA President decision.
• MNE groups must appoint a Designated Local Entity (DLE) responsible for registration, filing the GloBE Information Return (GIR), and managing DMTT and IIR payments.

Reporting and Filing Deadlines

• The GIR must be submitted within 15 months after the end of the reporting fiscal year (18 months in the transition year).
• If filed in another jurisdiction, a GIR notification must be submitted locally in Qatar.
• DMTT and IIR returns share the same filing deadline as the GIR.
• Further guidance on advance DMTT payments is expected from the GTA.

Basis of Calculation

• DMTT must be calculated using Financial Accounting Net Income or Loss and the presentation currency of the Ultimate Parent Entity’s consolidated financial statements.
• Domestic CEs are jointly and severally liable for DMTT payable in Qatar.
• Joint ventures have separate liability for their portion of the top-up tax.
• Separate effective tax rate (ETR) and top-up tax calculations apply to domestic JVs, stateless CEs, permanent establishments, and minority-owned CEs.

Special Provisions

• The Minister of Finance may grant zero-rate DMTT relief for MNE groups in their “Initial Phase of International Activity”, provided no Qatari entity is owned by a parent subject to a Qualified IIR abroad.
• Qatar will rely on the OECD Central Record to determine other jurisdictions’ qualifying status and safe harbour eligibility.

Background and Policy Context

Qatar’s implementation of the GloBE rules aligns with global efforts to establish a coordinated international minimum tax framework under BEPS 2.0 Pillar Two. By adopting the DMTT, Qatar ensures that the right to tax profits generated within the country remains with Qatar rather than foreign jurisdictions. At the same time, the IIR strengthens the ability of Qatar‑headquartered groups to recognise and tax low‑taxed foreign income, protecting them from exposure to the Undertaxed Profits Rule (UTPR) in foreign jurisdictions.

This legislation places Qatar among the leading Gulf Cooperation Council (GCC) jurisdictions that have formally enacted GloBE‑aligned rules, signaling the country's ongoing commitment to international tax transparency and equitable tax competition.

Implications for Multinational Groups in Qatar

The introduction of the Qatar Global Minimum Tax regime has significant implications for multinational enterprises operating in Qatar. Businesses must assess how the Domestic Minimum Top-up Tax and Income Inclusion Rule impact their effective tax rate, financial reporting systems, data infrastructure, and cross-border structuring.

Key next steps include:

• Confirming whether the €750 million consolidated revenue threshold is met
• Identifying all in-scope constituent entities and joint ventures
• Ensuring systems capture GloBE-compliant financial data
• Preparing for GIR, DMTT and IIR compliance obligations
• Monitoring further regulatory guidance from the General Tax Authority

How BDO Qatar Supports OECD Pillar Two Compliance

With the implementation of the Qatar Global Minimum Tax and DMTT regime, proactive compliance planning is essential. BDO Qatar provides specialised advisory services in OECD Pillar Two implementation, effective tax rate modelling, readiness assessments, data system alignment, and regulatory compliance support.

For tailored guidance on Qatar Global Minimum Tax, Domestic Minimum Top-up Tax (DMTT), and OECD Pillar Two compliance obligations, please contact our BDO Qatar tax advisory team.
 

Essam Mohamed
Senior Tax Manager
Doha, State of Qatar
essam.mohamed@bdo.com.qa

Kartik Parmar
Associate Partner
Doha, State of Qatar
kartik.parmar@bdo.com.qa

Gavin Brown
Managing Partner
Doha, State of Qatar
gavin.brown@bdo.com.qa