Qatar introduces a “Trusted Entity” regime to facilitate direct application of tax treaty benefits

17 March 2026 – The State of Qatar has issued Council of Ministers Decision No. (4) of 2026, amending certain provisions of the Executive Regulations of the Income Tax Law (Law No. 24 of 2018). The amendments introduce a new framework enabling the direct application of tax treaty benefits at source through entities approved by the General Tax Authority (GTA) as “Trusted Entities.”

The decision was published in the Official Gazette on 15 March 2026 and is effective from the day following its publication.

Key developments
The amendments introduce a mechanism allowing eligible Qatari taxpayers designated as Trusted Entities to apply double taxation treaty relief in advance at the time of payment to non-resident recipients in treaty jurisdictions.

Historically, non-resident taxpayers seeking treaty relief in Qatar were generally required to follow a withhold-and-refund process, whereby withholding tax was first applied under domestic law and the non-resident subsequently submitted a refund claim to the GTA to obtain treaty benefits and obtain the refund.

The newly introduced framework aims to streamline this process by allowing treaty benefits to be applied directly at source, subject to certain conditions and compliance requirements.

Trusted Entity regime
Under the amended regulations, a Trusted Entity refers to a taxpayer approved by the GTA that is permitted to apply treaty benefits when making payments to non-residents in contracting states.

To obtain Trusted Entity status, an applicant must:

• Be registered with the GTA
• Demonstrate sufficient administrative, financial, and technical capacity to comply with the obligations associated with the regime as prescribed in the regulations
• Meet thresholds relating to the volume or value of transactions subject to withholding tax, as determined by the President of the GTA

Applications are required to be submitted to the GTA using the prescribed form together with supporting documentation.

Trusted Entity status may be granted for a period of three years, subject to renewal. The GTA retains the authority to withdraw the status in cases of non-compliance.

Conditions for direct treaty relief

In order for treaty benefits to be applied at source, the non-resident recipient must provide the Trusted Entity with documentation confirming eligibility for treaty relief. This includes:

• Confirmation that the recipient is a resident of a treaty jurisdiction
• Evidence that the recipient is the beneficial owner of the income
• Confirmation that the income is not attributable to a permanent establishment in Qatar
• A valid tax residency certificate issued by the relevant foreign tax authority
• Confirmation that the arrangement is not established primarily to obtain treaty benefits

The Trusted Entity is required to exercise appropriate due diligence when assessing such requests and must retain relevant supporting documentation.

Compliance and reporting obligations

Trusted Entities will be subject to a number of compliance and reporting requirements, including:

• Maintaining documentation supporting the application of treaty benefits
• Providing information to the GTA regarding payments made under the regime
• Ensuring that treaty relief is applied only where conditions under the relevant tax treaty are satisfied

Failure to meet the requirements of the regime or misuse of treaty benefits may result in withdrawal of Trusted Entity status and potential tax liabilities.

Implications

The introduction of the Trusted Entity regime represents a significant development in the administration of tax treaty benefits in Qatar. If implemented effectively, the regime may:

• Reduce the administrative burden associated with withholding tax refund claims
• Improve cash flow for non-resident taxpayers
• Enhance the efficiency of cross-border payment processes
• Align Qatar’s practices with mechanisms adopted in other jurisdictions that allow treaty relief at source through certified intermediaries

Businesses making cross-border payments from Qatar, as well as multinational groups receiving payments from Qatari entities, should assess the potential implications of the new framework and consider whether obtaining Trusted Entity status may be beneficial.

Deloitte’s view

The introduction of a Trusted Entity mechanism signals a continued effort by Qatar to modernize its tax administration and facilitate the practical application of tax treaties. The framework may reduce reliance on refund-based treaty claims while strengthening the GTA’s oversight through eligibility criteria and due diligence obligations placed on Trusted Entities.

Further guidance from the GTA is expected to clarify operational aspects of the regime, including application procedures and compliance expectations.