Amendments to the Income Tax Law added a chapter on the global and domestic minimum top-up tax, implementing the OECD rules against base erosion and profit shifting. This chapter applies to multinational entity groups and raises the domestic tax liability on excess local profits to 15%, effective for fiscal years starting on or after 2025/01/01.
The Income Inclusion Rule and the Domestic Minimum Top-Up Tax
The law provides that the income inclusion rule applies to multinational entity groups operating in the state, and that a domestic minimum top-up tax applies to constituent entities located in the state. The domestic minimum top-up tax is defined as a tax calculated on the basis of the excess profits of local constituent entities in a manner consistent with the global anti-base erosion model rules, raising the domestic tax liability on excess local profits to 15%.
Who Do These Rules Cover?
The income inclusion rule and the domestic minimum top-up tax apply to constituent entities that are members of a multinational entity group with annual revenue of EUR 750 million or more in the consolidated financial statements of the ultimate parent entity, in at least two of the four fiscal years immediately preceding the tested fiscal year.
Interpretation Consistent With International Rules
The law requires that the income inclusion rule and the domestic minimum top-up tax be interpreted and applied consistently with the global anti-base erosion model rules, the commentary, and the agreed administrative guidance, including the rule order and any safe harbours, and amendments to that commentary apply automatically unless the Council of Ministers issues a decision excluding their application.
Effective Date: Fiscal Years From 2025/01/01
The provisions of this chapter apply only to fiscal years starting on or after 2025/01/01, and Cabinet Decision No. (2) of 2026 on the controls for applying the global and domestic minimum tax was issued confirming its application from that date.
Financial Penalties Under This Chapter
Any taxpayer who does not submit the returns required under this chapter within the prescribed period is subject to a financial penalty of 500 QAR for each day of delay, capped at 180,000 QAR. Any taxpayer who does not pay the top-up tax due within the prescribed period is subject to a financial penalty of 2% of the tax due for each month of delay or part thereof, not exceeding the amount of the tax due. A penalty of 20,000 QAR is also imposed on anyone who violates the registration and notification provisions of this chapter.
Legal References
- Law No. (24) of 2018 Promulgating the Income Tax Law — Article 23 bis
- Law No. (24) of 2018 Promulgating the Income Tax Law — Article 23 bis 1
- Law No. (24) of 2018 Promulgating the Income Tax Law — Article 23 bis 2
- Law No. (24) of 2018 Promulgating the Income Tax Law — Article 23 bis 3
- Law No. (24) of 2018 Promulgating the Income Tax Law — Article 23 bis 7
- Law No. (24) of 2018 Promulgating the Income Tax Law — Article 23 bis 8
- Cabinet Decision No. (2) of 2026 Issuing the Controls for Applying the Global and Domestic Minimum Tax — Article 2
- Pillar Two Regulations - Decision No. 2 of 2026 (EN, GTA) — Article 1.1.1 / Definitions
For questions about your specific situation, you can ask the Qatar Tax & Legislation Helper on Helpers, or consult a licensed chartered accountant.