Qatar Pillar 2 – New decisions issued in the Official Gazette on 27 August 2026
Qatar's General Tax Authority (GTA) has issued six administrative decisions implementing the country's Global and Domestic Minimum Tax (Pillar Two) framework, each applying to fiscal years starting on or after 1 January 2025. The decisions were signed on 10 May 2026 and published in Issue 14 of the Official Gazette dated August 27, 2026. Together, they establish the operational architecture within which multinational enterprise (MNE) groups and joint venture (JV) groups operating in Qatar will be required to adopt to comply with Qatar's Income Inclusion Rule (IIR) and Domestic Minimum Top-Up Tax (DMTT).
For fiscal years commencing in 2025, registration must be completed within three months from the date the GTA announces that the electronic platform is operational. Groups with Qatar operations should begin preparing immediately.
At a glance - The six decisions
Decision |
Topic |
What you need to know |
Key date |
17/2026 |
Currency conversion |
IIR and DMTT top-up taxes must be converted to QAR using the FX rate on the last day of the fiscal year. QCB rates are primary; ECB is fallback; Authority-approved third-party rates apply as a last resort. |
FYs from |
18/2026 |
Simplified reporting |
The transitional simplified jurisdictional reporting framework applies to all fiscal years beginning on or before 31 December 2028, excluding any fiscal year ending after 30 June 2030. Net reporting allowed where no entity-by-entity top-up tax allocation is required. |
FYs from |
19/2026 |
CbC safe harbor |
Top-up tax deemed zero if one of three tests is met: De Minimis (revenue < €10m and profit < €1m); Simplified ETR ≥ Transition Rate; or Routine Profits (profit ≤ substance-based income exclusion). Transition Rate is 16% for FY2025 and 17% for FY2026–2027. |
FYs |
20/2026 |
Non-material entities |
A filing constituent entity may make an annual election to determine GloBE Income or Loss, GloBE Revenue, and Adjusted Covered Taxes of a Non-Material Constituent Entity using simplified calculations. |
FYs from |
21/2026 |
Designated local entity |
Establishes the framework for appointment, responsibilities, and safeguards for Designated Local Entities of MNE Groups and JV Groups operating in Qatar. Material changes must be notified within 60 days. Payments by the former DLE are credited to the new DLE; in cases of partial payment, joint and several liability applies until full settlement. |
Annual |
22/2026 |
Registration |
At least two authorized representatives and a nominated Qatar tax representative must be included in the registration. If a group fails to register, the GTA may register it on an unofficial basis. |
3 months |
Three things to do right now
- Appoint your Designated Local Entity If the UPE is located in Qatar, it is automatically the DLE unless another domestic constituent entity is appointed. If the UPE is not in Qatar, the group must elect a DLE from its domestic constituent entities; where only one domestic constituent entity exists, it is automatically deemed the DLE, and the DLE must not be subject to insolvency proceedings. Confirm legal authority and data access documentation now.
- Prepare your registration data Registration requires full legal name, address, and tax identification number of the UPE; DLE details; domestic constituent entities and JV members (including entity classification); and ownership structure information. The 3-month window from platform launch is tight.
- Assess safe harbor eligibility The transitional CbC safe harbor is the most valuable near-term tool for most groups, but all data used, total revenue, profit before tax, income tax expense, payroll, and asset values, must come from the same type of Qualified Financial Statements. Review any financing or restructuring arrangements entered after 18 December 2023 for potential hybrid arbitrage adjustments.
Watch points
- Jurisdictions that did not benefit from the safe harbor in a previous fiscal year in which the MNE group was in scope are generally excluded from re-qualifying, unless the group had no constituent entities there in the prior year.
- A change in DLE does not extinguish liability for top-up tax amounts preceding the designation change.
- A DLE change cannot be used to achieve tax arbitrage, deferment, or avoidance; the GTA may reject any change it deems abusive.
- Failure to register is subject to penalties under the Income Tax Law, though transitional penalty relief under Article 4 of Law No. 22 of 2024 may apply.
How Deloitte can help
The Deloitte Middle East Tax practice and our Deloitte Qatar team stand ready to assist you with:
- Assessing your group's in-scope position under Qatar's Pillar Two framework
- Identifying and structuring your Designated Local Entity governance and data access arrangements
- Preparing for initial registration and DLE appointment ahead of the platform launch
- Analyzing safe harbor eligibility across your Qatar operations using CbC data
- Reviewing post-December 2023 arrangements against the Hybrid Arbitrage rules
- Designing compliant FX translation methodologies and documentation
