The guidance details Qatar's Global and Domestic Minimum Tax framework, aligned with the OECD's Pillar Two rules, requiring multinational enterprises with annual revenues exceeding EUR 750 million to pay a minimum effective tax rate of 15% on profits, with the regime in force for fiscal years beginning on or after 1 January 2025. 

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The Qatar General Tax Authority (GTA) has released guidance on the Pillar Two Global Minimum Tax, including user manuals, relevant legislation and regulations, and a set of frequently asked questions (FAQs).

Qatar’s Global Minimum Tax

Qatar’s Global and Domestic Minimum Tax reflects Qatar’s strong commitment to international tax standards and alignment with the OECD’s Pillar Two framework. Qatar’s Global and Domestic Minimum Tax Resolution provide detailed information about the Income Inclusion Rule (IIR) and the Domestic Minimum Top-Up Tax (DMTT), effective for Fiscal Years commencing on or after 1 January 2025.

Under Qatar’s implementation of Pillar Two, Multinational Enterprises with annual revenues exceeding EUR 750 million in two out of the last four years, will generally be subject to a minimum effective tax rate of at least 15% in Qatar on:

  • profits of Constituent Entities and GloBE Joint Ventures located in Qatar, and
  • profits of lower-tier Constituent Entities and GloBE Joint Ventures located outside Qatar if they are not already subject to an effective tax rate of 15%

FAQs

What laws govern Pillar Two in Qatar?

Pillar Two in Qatar is governed by Law No. 22 of 2024, which amended the Income Tax Law (No. 24 of 2018), and the Resolution of the Council of Ministers No. 2 of 2026 Issuing the Rules for the Application of the Global and Domestic Minimum Taxes (“Resolution”) (jointly implementing Qatar Global and Domestic Minimum Tax framework, referred also as “Qatar Pillar Two Framework”).

What is the Qatar Pillar Two Framework?

The Qatar Pillar Two Framework is Qatar’s implementation of the OECD’s global minimum tax, ensuring large Multinational Entity Groups generally pay at least a 15% Effective Tax Rate on profits in every jurisdiction where they operate.

Why did Qatar adopt Pillar Two?

Qatar adopted Pillar Two to combat base erosion and profit shifting, to align with international tax standards, and to ensure fair taxation by large multinational entity groups.

What are the main charging mechanisms under the Qatar Pillar Two Framework?

Qatar applies two charging mechanisms: the Domestic Minimum Top-Up Tax (DMTT) for Qatar-located entities and the Income Inclusion Rule (IIR) for Parent Entities located in Qatar.

What is the minimum tax rate under Pillar Two?

The minimum Effective Tax Rate is 15% for in-scope Multinational Entity Groups.

Who administers Pillar Two in Qatar?

The General Tax Authority (the Authority) has the primary responsibility for ensuring compliance and enforcement of the Qatar Pillar Two Framework.

Does the Qatar Pillar Two Framework replace Qatar’s existing income tax?

No, the Qatar Pillar Two Framework applies in addition to existing income tax rules; it does not replace them.

What is the objective of the Qatar Pillar Two Framework?

The objective is to ensure large Multinational Entity Groups pay a minimum tax on profits, preventing profit shifting to low-tax jurisdictions.

Is the Qatar Pillar Two Framework aligned with OECD standards?

Yes, Qatar’s Pillar Two Framework closely follows the OECD Global Anti-Base Erosion (GloBE) Model Rules.

Which entities are subject to the Qatar Pillar Two Framework?

Entities that are members of a Multinational Entity Group with annual consolidated Revenue of at least EUR 750 million in at least two of the four preceding tested fiscal years.