Qatar's General Tax Authority released six Pillar Two decisions on 27 August 2026, covering currency conversion, simplified reporting for 2025–2030, safe harbour exemptions for low-risk jurisdictions, and registration protocols requiring multinational groups to register within three months for 2025. All provisions apply from 1 January 2025.
Qatar published six General Tax Authority (GTA) decisions in Issue 14 of the Official Gazette on 27 August 2026, setting out rules for implementing the Pillar Two global minimum tax framework.
A primary focus is the Ministry of Foreign Affairs’ comprehensive guide for the description and classification of diplomatic and consular roles, outlining the formal hierarchy and career progression. These regulations establish specific appointment criteria, such as language proficiency and academic credentials, while also defining the minimum years of service required for professional promotion.
Decision No. (17) on currency conversion rules
This decision governs how multinational enterprise (MNE) groups translate their financial figures to satisfy the compliance requirements of Qatar’s minimum tax framework.
Qatar’s minimum tax framework decision establishes currency translation rules for multinational enterprise groups calculating their Qualified Domestic Minimum Top-Up Tax (QDMTT) and Income Inclusion Rule (IIR) obligations.
Groups must align both computations to their consolidated financial statement presentation currency and follow a prescribed exchange rate hierarchy: Qatar Central Bank rates first, then European Central Bank rates, then approved third-party sources. Threshold amounts translate to Euro using December average rates from the year before the fiscal year starts, and final tax liabilities convert to Qatari Riyal at fiscal year-end rates for settlement.
The rules apply to all fiscal years beginning on or after 1 January 2025.
Decision No. (18) on simplified reporting procedures
This decision introduces simplified compliance measures for MNE groups during a transitional phase, balancing administrative relief with robust audit safeguards.
MNE groups can use a simplified compliance framework for fiscal years 2025–2030, reporting GloBE adjustments on a net basis rather than entity-by-entity. This relief applies only where no Top-Up Tax liability arises; jurisdictions with such liabilities require detailed constituent-level reporting. Groups must maintain capable accounting systems, reliable allocation processes, and contemporaneous documentation. Tax authorities retain full audit and information-gathering rights regardless of the simplified approach.
The framework takes effect 1 January 2025.
Decision No. (19) on transitional CbC safe harbour
This decision outlines the transitional safe harbour rules designed to reduce the compliance burden in low-risk jurisdictions.
The transitional safe harbour exempts tested jurisdictions from Pillar Two top-up tax calculations if they meet one of three conditions: annual revenue below EUR 10 million and profit below EUR 1 million; a simplified effective tax rate of 16–17% depending on fiscal year; or routine profits within substance-based limits.
The scheme runs through fiscal years ending by 30 June 2029. Critical safeguards include mandatory consistency in financial statement types across all entities in a jurisdiction (mixing sources disqualifies the jurisdiction), neutralisation of hybrid arbitrage arrangements entered into after 18 December 2023, and exclusion of net unrealised fair value losses exceeding EUR 50 million.
A “once out, always out” provision permanently bars any MNE group that failed to claim or qualify for the safe harbour in a prior year from future claims for that jurisdiction.
The rules take effect for fiscal years beginning 1 January 2025.
Decision No. (20) on simplified NMCE calculations
A new decision allows filing constituent entities to elect annually to use simplified calculations for their Non-Material Constituent Entities (NMCEs) under GloBE rules. Rather than apply default GloBE values, benefiting entities may substitute Country-by-Country revenue figures for Global Anti-Base Erosion Income and Revenue, and use accrued income tax expense from CbC reporting for Adjusted Covered Taxes.
The measure takes effect for all fiscal years commencing on or after 1 January 2025.
Decision No. (21) on designated local entity (DLE)
This decision defines how a designated local constituent entity represents the MNE group for Qatari tax administrative purposes.
Qatar’s tax authority designates one entity (DLE) per group to handle all compliance obligations—registrations, Pillar Two filings, and tax payments. When a DLE is replaced, the new entity assumes full responsibility for prior unpaid liabilities and shares joint liability with its predecessor.
If a DLE fails to act, other domestic group members must file returns or pay taxes within 60 days of GTA notice. A critical issue exists in the DLE replacement timeline: the English version requires a successor appointment within 60 days of disqualification, while the Arabic version (legally binding in Qatar) mandates 30 days.
The requirements apply to all fiscal years commencing on or after 1 January 2025.
Decision No. (22) on registration requirements
This decision establishes the administrative protocols for registration, updates, and deregistration under the minimum tax rules.
Multinational enterprise groups must register with the GTA through an electronic platform within three months of its launch for the 2025 fiscal year, then annually within six months of each subsequent year-end. The GTA may register groups unilaterally if they miss these deadlines. Groups that cease to qualify must apply for deregistration with supporting documentation. Non-compliance incurs penalties under the Income Tax Law, though transitional relief applies under Article 4 of Law No. 22/2024.
The framework takes effect for all fiscal years starting 1 January 2025 onwards.
