Qatar has formally adopted the OECD's Pillar Two global minimum tax. Through Council of Ministers Resolution No. (2) of 2026, Qatar has introduced both the Global Minimum Tax and a Domestic Minimum Top-Up Tax (DMTT). The regulation closely follows the OECD's Global Anti-Base Erosion (GloBE) Model Rules, and it applies to financial years beginning on or after 1 January 2025.
Key takeaways
- Qatar implemented Pillar Two through Council of Ministers Resolution No. (2) of 2026, adding Chapter VII Bis to the Income Tax Law (Law No. 24 of 2018).
- The rules apply to multinational groups with consolidated annual revenue of at least EUR 750 million, met in at least two of the four preceding years.
- A Domestic Minimum Top-Up Tax ensures a minimum effective tax rate of 15% on Qatar-based income and keeps the resulting top-up tax in Qatar.
- The rules take effect for financial years beginning on or after 1 January 2025, so affected groups must prepare for FY2025 compliance now.
- The top-up tax is calculated as 15% minus the jurisdictional effective tax rate, following the GloBE methodology.
What Pillar Two does, in brief
Pillar Two is the OECD's mechanism for setting a floor under corporate tax competition. It aims to ensure that large multinational groups pay a minimum effective tax rate of 15% in every jurisdiction where they operate, measured on a jurisdiction-by-jurisdiction basis. Where a group's effective rate in a country falls below 15%, a "top-up tax" makes up the difference. The wider purpose is to address base erosion and profit shifting and to align Qatar's framework with global BEPS and minimum-tax initiatives — while, importantly, preserving Qatar's own right to collect the tax.
Who is in scope for Qatar's Pillar Two?
Qatar's Pillar Two rules apply to multinational groups with consolidated annual revenue of at least EUR 750 million, met in at least two of the four preceding fiscal years. That standard GloBE threshold decides whether a group has any obligation at all, and the table breaks it into its component parts.
| Scope test | Requirement |
|---|---|
| Revenue threshold | Consolidated annual revenue of at least EUR 750 million |
| Look-back | Threshold met in at least two of the four preceding fiscal years |
| Short or long years | Threshold is adjusted proportionately for non-standard fiscal years |
Groups below EUR 750 million are outside the regime. Those above it — even if only their global figure crosses the line — need to test their Qatari effective rate, regardless of how profitable the Qatari entities are in isolation.
The Domestic Minimum Top-Up Tax
The centrepiece for locally based entities is the DMTT, which applies to constituent entities located in Qatar. Its logic is defensive: rather than let another country collect top-up tax on low-taxed Qatari profit, Qatar collects it first.
The DMTT is intended to ensure that any top-up tax on Qatari income is collected domestically, rather than by other jurisdictions under the Income Inclusion Rule or the Undertaxed Profits Rule.
The DMTT's key features are a guaranteed minimum effective rate of 15% on Qatar-based income, joint and several liability among the Qatar-based constituent entities, and the ability to designate a single entity to file returns and make payments on behalf of the domestic group. That designation is a practical convenience, but the joint liability means every Qatari entity in the group has an interest in the numbers being right.
How the top-up tax is calculated
The computation is aligned with the GloBE Rules and runs in a set sequence. It starts from Financial Accounting Net Income taken from the consolidated financial statements, applies GloBE adjustments to arrive at GloBE Income or Loss, and then calculates the effective tax rate on a jurisdictional basis. The top-up tax is the shortfall — 15% minus that effective rate — subject to the applicable exclusions. Figures are kept in the consolidated statements' presentation currency and translated into Qatari Riyal as prescribed. Because the starting point is accounting data rather than the tax return, finance and tax functions have to work from the same reconciled source, which is where reliable tax automation tooling earns its keep.
Compliance obligations and practical impact
The regulation empowers the Qatar Tax Authority to prescribe the Pillar Two returns and disclosures, the filing and payment mechanics, and further administrative guidance. Qatar-based constituent entities may be required to designate a filing and paying entity for DMTT purposes, maintain documentation supporting their GloBE calculations and elections, and comply with future guidance on timelines and reporting.
For affected groups the practical impact is broad. Entities may face additional tax where their effective rate falls below 15%, along with heavier data, reporting and systems requirements and greater scrutiny of group structures, intragroup transactions and deferred-tax positions. Early impact assessment is the difference between a managed compliance exercise and a scramble, and it connects directly to the group's corporate tax and international tax planning. In practice, SBC starts these engagements by reconciling the finance-side accounting data to the GloBE inputs, because that mapping, not the rate, is where most first-year DMTT projects stall.
Frequently asked questions
Who does Qatar's Pillar Two apply to?
Qatar's Pillar Two rules apply to multinational enterprise groups with consolidated annual revenue of at least EUR 750 million, where that threshold has been met in at least two of the four preceding fiscal years. Groups below the threshold are outside the regime, and the threshold is adjusted proportionately for short or long fiscal years.
When did Qatar's global minimum tax take effect?
The rules apply to financial years beginning on or after 1 January 2025. In-scope groups are therefore already within the first affected period and need to prepare for FY2025 compliance, including the data and documentation required for GloBE calculations.
What is Qatar's Domestic Minimum Top-Up Tax (DMTT)?
The DMTT applies to constituent entities located in Qatar and ensures a minimum effective tax rate of 15% on Qatar-based income. It allows Qatar to keep any top-up tax domestically rather than ceding it to other jurisdictions, and it imposes joint and several liability among Qatar-based entities, with the option to designate one entity to file and pay.
How is the Qatar top-up tax calculated?
Following the OECD GloBE methodology, the calculation begins with Financial Accounting Net Income from the consolidated financial statements, applies adjustments to reach GloBE Income or Loss, and computes the jurisdictional effective tax rate. The top-up tax equals 15% minus that effective rate, subject to applicable exclusions, expressed in Qatari Riyal.
How SBC Tax Consulting can help
SBC supports multinational groups through Pillar Two impact and exposure assessments, DMTT readiness reviews and gap analysis, GloBE data mapping and calculation support, and compliance-framework and reporting design. Our international tax specialists translate the GloBE rules into a workable process across finance and tax, and advise on governance and documentation as further guidance is issued. To assess your Qatar Pillar Two exposure, contact our advisors.
This publication is for general information only and does not constitute professional advice. Please consult your SBC advisor before acting on any matter covered here.