Key Points:
- Law No. 22 of 2024 amends Qatar’s Income Tax Law (Law No. 24 of 2018) to introduce the Domestic Minimum Top-Up Tax (DMTT) and Income Inclusion Rule (IIR) under OECD Pillar Two.
- Applies to multinational enterprise (MNE) groups with consolidated annual revenue of at least €750 million in at least two of the prior four fiscal years.
- DMTT ensures that Qatar‑sourced profits of in-scope MNEs are taxed to a minimum effective rate of 15%, even if other incentives make the underlying tax lower.
- IIR allows a Qatari parent (or an intermediate Qatari entity) to “top up” tax on low-taxed foreign subsidiaries, aligning with OECD Globe rules.
- Effective for fiscal years starting on or after 1 January 2025.
- Penalties for non‑compliance:
- Late filings: QAR 500/day (capped at QAR 180,000)
- Late payments: 2% monthly on unpaid top-up tax
- Failure to register: fixed penalty of QAR 20,000
- Qatar offers a transitional penalty relief regime for fiscal years beginning on or before 31 December 2026, if in good faith the group takes steps to comply.
- The amendments apply across all jurisdictions in Qatar, including Free Zones, Qatar Financial Centre (QFC), and other special zones.
Disclaimer: The Content offer general guidance and should not be considered legal, financial, or tax advice. Consult qualified professionals for personalized guidance. While efforts have been made to ensure accuracy, no guarantee is provided for completeness or applicability to individual situations. Users are responsible for their interpretation and actions based on this information, at their own risk.
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This article was published on 27 December 2025.
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