Qatar Opens Minimum-Tax Registration as 15% Pillar Two Rules Take Effect
Qatar’s General Tax Authority opened registration on 2 August for the global and domestic minimum tax, giving multinational groups three months from the activation of the service on the Dhareeba platform to complete their initial registration. The rules themselves have been in force since fiscal years beginning on or after 1 January 2025, which makes this the operational step rather than the policy one.
The regime applies a minimum effective tax rate of 15 per cent to multinational enterprise groups with consolidated annual revenues of at least EUR 750 million in at least two of the four fiscal years preceding the tested year. Registration is completed by a designated local entity appointed by the group to discharge its registration, notification and filing obligations, and covers the group’s core information, the identification and location of the ultimate parent entity, and the constituent entities within scope.
What Qatar has adopted
| Element | Position |
|---|---|
| Minimum effective rate | 15 per cent on excess profit in each jurisdiction of operation |
| Scope threshold | EUR 750 million consolidated revenue in at least 2 of the 4 preceding fiscal years |
| Charging mechanisms adopted | Two — the Domestic Minimum Top-Up Tax and the Income Inclusion Rule |
| Effective from | Fiscal years beginning on or after 1 January 2025 |
| Initial registration window | Three months from activation of the Dhareeba service |
| Return filing | 15 months after fiscal year end; 18 months for the transition year |
| Transitional penalty relief | Fiscal years beginning on or before 31 December 2026, excluding any fiscal year ending after 30 June 2028 |
The legislative framework is Law No. (22) of 2024, which amended the Income Tax Law No. 24 of 2018 and introduced a new chapter on the global and domestic minimum taxes. The operative rules sit in Resolution of the Council of Ministers No. (2) of 2026, which applies to fiscal years beginning on or after 1 January 2025.
Two points of precision are worth making, because both are commonly overstated. The authority has not published a calendar activation date distinct from the announcement date, so the three-month clock has no published start and no fixed deadline can be quoted. And the authority describes two charging mechanisms; it makes no statement at all about an undertaxed profits rule, which is therefore best read as not provided for rather than as expressly declined.
Where the Gulf stands
| Country | Rules adopted | Effective from |
|---|---|---|
| Qatar | Domestic Minimum Top-Up Tax and Income Inclusion Rule | Fiscal years from 1 January 2025 |
| United Arab Emirates | Domestic Top-up Tax only; the Income Inclusion Rule was expressly not implemented, the Ministry of Finance citing the absence of a controlled foreign company regime | Financial years from 1 January 2025 |
| Bahrain | Domestic minimum top-up tax only, at 15 per cent, under Decree-Law No. (11) of 2024 on the regulation of tax on multinational enterprises; the charge falls only on Bahrain-located constituent entities | 1 January 2025, per the World Bank |
The table is deliberately confined to the three Gulf states whose position can be quoted from their own instruments. Kuwait, Oman and Saudi Arabia are omitted rather than characterised: the Kuwaiti and Omani texts could not be opened at an official domain, and no Saudi originator publishes a Pillar Two instrument or a consultation on one.
The United Arab Emirates announced in August 2025 that the OECD had published its domestic minimum top-up tax on the central record of legislation with transitional qualified status, a step that brings safe-harbour treatment and a lighter administrative load for groups and for the tax administration alike.
Why it matters: The Gulf has moved from being a set of jurisdictions where large multinationals paid little or no corporate tax to one where a 15 per cent floor is the operating assumption for groups above the threshold. Qatar’s design choice is the notable part. By taking both a domestic top-up tax and an income inclusion rule, it collects the top-up on its own soil rather than leaving it to be picked up elsewhere, and it also reaches the foreign low-taxed profits of Qatari-parented groups. The competitive question for the region is no longer the headline rate, which is converging, but the quality of the administration around it: registration mechanics, filing windows and the predictability of relief.
Outlook: Two milestones are worth tracking. The first is whether the OECD adds Qatar’s domestic top-up tax to the central record with transitional qualified status, which would give in-scope groups safe-harbour treatment; Qatar’s own materials describe its rules as qualified, but that is Qatar’s characterisation and not an OECD determination. The second is the publication of an activation date for the Dhareeba service, which is what converts a three-month window into a real deadline for finance teams now doing the work.
Sources: Qatar General Tax Authority announcement of 2 August 2026, Global Minimum Tax pages and Pillar Two framework guidance; Resolution of the Council of Ministers No. (2) of 2026; Law No. (22) of 2024; United Arab Emirates Ministry of Finance; Kingdom of Bahrain Legislation and Legal Opinion Commission, Decree-Law No. (11) of 2024; World Bank Group, Gulf Economic Update.
