In brief
Qatar has implemented Pillar Two through Law No. 22 of 2024 (Qatar Pillar Two Law), introducing the Income Inclusion Rule (IIR) and a Domestic Minimum Top-up Tax (DMTT), effective from 1 January 2025. The law aligns with the OECD GloBE Model Rules, Commentary and Agreed Administrative Guidance.
On 12 February 2026, the Council of Ministers issued a Resolution amending the Executive Regulations and setting out detailed rules for applying the IIR and DMTT. As expected, the framework is closely aligned with the OECD GloBE Model Rules. Qatar has also been recognised by the OECD as having a qualified IIR and DMTT regime.
The rules apply to Multinational Enterprise (MNE) Groups with consolidated global revenues of at least EUR 750 million in at least two of the four preceding fiscal years. This includes:
- Qatar-headquartered groups with operations outside Qatar; and
- Foreign-headquartered MNEs with operations in Qatar.
Purely domestic Qatar groups are outside the scope.
Notification deadlines will be confirmed in a forthcoming Decision from the President of the General Tax Authority (GTA). The Executive Regulations confirm that no notification will be due before 30 June 2026.
Below, we outline the key features of the IIR and DMTT, together with our initial observations and practical considerations.
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Pillar Two developments in Qatar
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Jochem Rossel
Partner, Middle East Tax & Legal Services Leader, PwC Middle East
Hanan Abboud
Sajid Khan
Jonathan Fraser
Chris Maycroft
Nikie van Duurling
Tatyana Rahmonova
Tatiana Shuldyk
Roy Kantari
Director - Pillar Two, PwC Middle East
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