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Qatar has introduced a 15% global minimum tax, often called Pillar Two, for large multinational groups. Finance teams in Qatar usually hear about it from head office or the group’s auditors, and the first question is simple: does our Qatar company or branch have to do anything?
The rules come from Law No. 22 of 2024, which amends the Income Tax Law, and from Council of Ministers Resolution No. 2 of 2026, which sets out the detailed rules. The General Tax Authority (GTA) has published guides and opened registration on Dhareeba.
This guide gives a four-question scope test and the registration and filing steps that follow. It does not cover how to compute the tax.
- Minimum rate
- 15%
- Group revenue
- EUR 750 million+
- Returns due
- 15 months after year end
- Law checked
- 16 October 2026
The short answer
In short
- Qatar applies a 15% minimum tax to entities of multinational groups whose consolidated revenue was EUR 750 million or more in at least two of the four previous fiscal years (Resolution No. 2 of 2026, Article 1.1.1), for fiscal years beginning on or after 1 January 2025.
- A Qatar subsidiary of such a group is in scope, and so in many cases is a Qatar branch. It is in scope even if the group expects no top-up tax.
- One Qatar entity, the Designated Local Entity, registers for the whole group on Dhareeba and then renews the registration each year.
- Small and medium-sized companies, and groups with all their entities in Qatar, are outside the rules.
The global minimum tax sits alongside the other taxes described in taxes in Qatar for companies.
What Pillar Two is, in brief
Pillar Two is based on the OECD’s Global Anti-Base Erosion (GloBE) Model Rules. Where a large group’s effective tax rate in a country is below 15%, a top-up tax brings the tax on its excess profits up to 15%. Under the OECD design, top-up tax is charged first by a qualified domestic minimum tax in the country where the profits arise, then by an income inclusion rule at the parent, then by an undertaxed profits rule.
Qatar applies two rules (Resolution Articles 1.1 and 2.1). The Domestic Minimum Top-Up Tax (DMTT) applies to in-scope entities located in Qatar, so that their Qatar profits bear at least 15%. The Income Inclusion Rule (IIR) applies to parent entities located in Qatar, for low-taxed entities of the group abroad, and it can also apply to intermediate or partially owned parents in Qatar.
These rules apply in addition to corporate income tax; they do not replace it (GTA FAQs, Q7). The GTA’s 2024 English edition of the Income Tax Law predates these provisions, so the GTA’s global minimum tax page, the Resolution and the GTA guides are the sources to use.
Is your Qatar entity in scope? Four questions
Answer these four questions with your group tax team. If all four answers are yes, the group has Pillar Two duties in Qatar.
Scope test
- 1. Revenue test. Did the ultimate parent’s consolidated financial statements show annual revenue of EUR 750 million or more in at least two of the four fiscal years before the year being tested? If a year was not 12 months, the threshold is adjusted in proportion (Resolution Articles 1.1.1 and 1.1.2).
- 2. Multinational test. Does the group have at least one entity or permanent establishment outside the ultimate parent’s country (Article 1.2.1)? A group whose entities are all in Qatar is not a multinational group under this definition.
- 3. Presence in Qatar. Does the group have a constituent entity in Qatar, meaning an entity or permanent establishment included in the consolidated statements (Article 1.3)? Entities in the Qatar Financial Centre, Qatar Free Zones, Qatar Science and Technology Park and Media City count if their group is in scope (GTA registration guide, section 2).
- 4. Not an excluded entity. Is the Qatar entity something other than an excluded entity, such as a governmental entity, international organisation, non-profit organisation, pension fund, or an investment fund or real estate investment vehicle that is an ultimate parent (Article 1.5)?
The revenue test is applied to the group, not to the Qatar entity. A Qatar company with modest revenue is still in scope if it belongs to a group that meets the test. Joint-venture groups are handled separately and register on their own.
Branches: when a Qatar branch counts
A permanent establishment (PE) is a constituent entity under the Pillar Two rules, but the Pillar Two definition differs from the one in the Income Tax Law (GTA FAQs, Q22). In short, a place of business is a GloBE PE if it is treated as a PE under a tax treaty, or, where there is no treaty, if the country taxes its income on a net basis under its domestic law. The definition has two further limbs for countries with no income tax and for exempt foreign operations.
A Qatar branch of a foreign company that files a Qatar tax return on its net profit is normally the kind of place of business the definition describes. Whether a particular branch is a GloBE PE still depends on the treaty position and on how the group consolidates it, so confirm the answer with the group tax team. Our tax advisory service covers permanent establishment questions for branches and subsidiaries of overseas groups, and our page on foreign company branches explains how branches are taxed in Qatar.
DMTT or IIR: which one applies to you
Which rule concerns you depends on where you sit in the group. A subsidiary or branch of a foreign group is concerned with the DMTT: if its Qatar profits are taxed below 15%, top-up tax is due in Qatar. A Qatar parent with entities abroad is concerned with the IIR for any of those entities taxed below 15% in their own countries, and with the DMTT for its Qatar entities.
The GTA’s own example is a Qatar subsidiary of an in-scope group with a 10% effective tax rate in Qatar: it pays DMTT so that the tax on those profits rises to 15% (GTA registration guide, section 1.2, Example 1). Corporate income tax in Qatar is 10% of taxable income (Income Tax Law Article 9), and the share of profits belonging to Qatari and GCC owners is exempt, so a Qatar entity of a large group can have an effective rate below 15%.
The yearly corporate income tax return continues as before; see how to file a corporate income tax return.
Registration on Dhareeba and the Designated Local Entity
Registration is group-based. The group appoints one Qatar constituent entity as its Designated Local Entity (DLE), which registers and handles filing and payment for the group, and a Qatar ultimate parent is the DLE unless it appoints another Qatar entity (GTA registration guide, sections 2.2 and 2.3). Pillar Two registration is a separate Dhareeba service from income tax, and the DLE needs an existing tax profile and TIN first; see Dhareeba registration and the tax card. Groups must register even if they expect no top-up tax, because a safe harbour or exclusion does not remove the duty to register, notify or file (guide section 2; FAQs, Q46).
The GTA announced the start of registration on Dhareeba on 2 August 2026. For fiscal years starting in 2025, the DLE registers within three months from the date the service was activated, so check the GTA page for the date that applies to your group. In later years, a group that first comes into scope from 2026 registers within six months after the end of that fiscal year, and registered groups renew every year within six months after year end, even if nothing has changed.
Filing and payment dates
| Obligation | Due | Calendar-year example | Source |
|---|---|---|---|
| First registration (groups in scope from FY2026) | 6 months after year end | 30 June 2027 for FY2026 | GTA guide s. 3 |
| Annual renewal of registration | 6 months after year end | 30 June 2027 for FY2026 | GTA guide s. 6.1 |
| DMTT return | 15 months after year end; 18 months for the first year | 30 June 2027 for FY2025 | GTA guide s. 8.2, 11 |
| IIR return, if any | 15 months; 18 months for the first year | 30 June 2027 for FY2025 | GTA guide s. 8.3, 11 |
| GloBE Information Return (GIR), or GIR notification | 15 months; 18 months for the first year | 30 June 2027 for FY2025 | Resolution Arts. 8.1, 9.4 |
| Payment of top-up tax | By the return deadline | 30 June 2027 for FY2025 | GTA guide s. 10.1 |
For a calendar-year group, 30 June 2027 is therefore a key date for several first-cycle filings. The Qatar compliance calendar 2027 places it among the other deadlines of the year.
Safe harbours and penalties in brief
Safe harbours and exclusions can reduce or remove top-up tax, but not the filing duties. They include the transitional country-by-country reporting safe harbour, which uses the group’s country-by-country report, and a de minimis exclusion for a country where the group’s average revenue is below EUR 10 million and average income below EUR 1 million, chosen each year (Resolution Articles 5.5 and 8.2). Our transfer pricing page covers country-by-country reporting.
The GTA guide lists these penalties: QAR 20,000 for failing to register; QAR 500 a day, up to QAR 180,000, for a late DMTT or IIR return; 2% of unpaid top-up tax for each month or part of a month, up to the tax due; and QAR 20,000 for GIR notification failures. The GTA may also register a group itself. Transitional relief from penalties exists for the first years where a group took reasonable steps to comply; it does not cover evasion or fraud.
What to do next
- 1
Confirm the revenue test
Ask head office for the consolidated revenue of the last four years.
- 2
List Qatar entities and branches
Include QFC and free zone entities and any branch that may be a GloBE PE.
- 3
Agree the DLE
Decide which Qatar entity registers for the group.
- 4
Check the tax card
Make sure the DLE has an active Dhareeba profile and TIN.
- 5
Diary the dates
Record the six-month registration or renewal date and the 15-month return date.
Our tax advisory service helps you understand how Qatar tax applies to your business, including branches and subsidiaries of overseas groups. To discuss your position, request a proposal.
Frequently asked questions
What is the global minimum tax rate in Qatar?
15%, as defined in Council of Ministers Resolution No. 2 of 2026. It applies on top of corporate income tax, not in place of it, and only to entities of in-scope multinational groups (GTA FAQs, Q7).
Does Pillar Two apply to small and medium-sized companies in Qatar?
No. It applies only to entities of multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four previous years (Resolution Article 1.1.1). A group with all its entities in Qatar is not a multinational group.
Does a Qatar branch of a foreign company fall under Pillar Two?
It can. A permanent establishment is a constituent entity under the Pillar Two rules, using its own definition rather than the income tax one (GTA FAQs, Q22). Confirm the position of your branch with the group tax team.
Do we have to register if we expect no top-up tax?
Yes. The GTA requires in-scope groups to register even if no top-up tax is expected, and a safe harbour or exclusion does not remove the registration, notification or filing duties (GTA registration guide, section 2; FAQs, Q46).
Who registers for Pillar Two in Qatar?
The Designated Local Entity, one Qatar constituent entity appointed by the group, registers on Dhareeba for the whole group. A Qatar ultimate parent is the DLE unless it appoints another Qatar entity (GTA registration guide, section 2.3).
When are the Pillar Two returns due?
The DMTT return, any IIR return and the GloBE Information Return are due 15 months after year end, or 18 months for the first year. Registration is renewed within six months after each year end (GTA registration guide, section 11).
Sources
Laws, regulations and GTA guidance
- Global minimum tax (General Tax Authority)
- Council of Ministers Resolution No. 2 of 2026, Pillar Two rules (General Tax Authority)
- Qatar Pillar Two Framework Guide: Registration and Compliance (General Tax Authority)
- Qatar Pillar Two Framework FAQs (General Tax Authority)
- Income Tax Law and Executive Regulations, 2024 edition, for corporate income tax (General Tax Authority)
Registration and international background
This article is general information, not tax advice for your group. The Resolution, GTA guides and pages cited were checked on 16 October 2026; the GTA updates its Pillar Two guidance, so check the GTA page before acting. English descriptions of Arabic texts are our own.