Law & Regulation
Resolution of the Council of Ministers No. 2 of 2026 Issuing the Rules for the Application of the Global and Domestic Minimum Taxes
The Resolution contains the detailed rules for applying Qatar's Income Inclusion Rule and Domestic Minimum Top-Up Tax. It translates the statutory Pillar Two amendment into a complete calculation, allocation, election, safe-harbour, filing, payment and administration framework.
Legal Significance
What This Instrument Does
Defines the operational GloBE system used to determine whether an MNE group is in scope, calculate jurisdictional effective tax rates and top-up tax, allocate liability, apply exclusions/elections and satisfy Qatar reporting and payment obligations. Published in the Official Gazette on 12 February 2026; applies to fiscal years beginning on or after 1 January 2025.
Why It Matters
Minimum tax is not calculated from the project company's nominal corporate rate alone. Consolidated financial accounts, group structure, entity classification, covered taxes, deferred tax and cross-border ownership can all affect the result.
Key Provisions
- Scope and group threshold
Tests for in-scope MNE groups, constituent entities and fiscal-year application.
- Excluded entities
Categories outside the charging system or subject to specific treatment.
- GloBE income or loss
Adjustments from financial accounting results to the minimum-tax base.
- Covered taxes
Identification and adjustment of taxes included in the effective-tax-rate numerator.
- Jurisdictional blending and ETR
Aggregation and effective-tax-rate computation by jurisdiction.
- Top-up-tax calculation
Mechanics for the top-up percentage, excess profits and jurisdictional amount.
- Substance-based income exclusion
Payroll and tangible-asset carve-out mechanics where conditions are met.
- DMTT architecture
Qatar domestic minimum top-up tax and its interaction with the wider ordering rules.
- IIR allocation
Allocation of top-up tax to qualifying parent entities.
- Ownership, JVs and special structures
Rules for partially owned, joint-venture, flow-through and other non-standard entities.
- Elections and safe harbours
Optional or transitional simplifications subject to conditions and current international guidance.
- Restructuring and asset transfers
Treatment of group entry/exit, mergers and specified transfers.
- Filing, payment and administration
Registration, information returns, tax returns, payment, records and GTA powers.
- Interpretation and international alignment
Application consistently with the relevant GloBE materials, subject to Qatar law.
When You Would Use This
Pillar Two scoping
Determining whether a group and entity are in scope.
Data-gap assessment
Identifying data required for GloBE calculations.
Financial-model and tax-provision work
Incorporating minimum-tax effects into financial models and provisions.
Sponsor-group reorganisations
Assessing minimum-tax effects of a group reorganisation.
Joint-venture analysis
Testing minimum-tax treatment of joint-venture structures.
Incentive review
Reviewing Qatar incentives against the minimum-tax layer.
Transaction due diligence
Incorporating Pillar Two exposure into transaction diligence.
Compliance calendars
Building compliance calendars for registration, returns and payment.
Tax cooperation duties
Allocating tax cooperation duties in project and finance documents.
InfraLex Relevance
The Resolution matters most at sponsor-group level, with downstream effects on project cash and covenants. InfraLex should present a decision path—scope, entity classification, GloBE income, covered taxes, ETR, top-up tax, charging rule, filing—rather than flattening the regime into a rate summary.
Legal Framework Position
- TaxImplementing Instrument
Instrument Overview
- Official Citation
- Council of Ministers Resolution No. 2 of 2026
- Instrument Type
- Regulation
- Source Language
- Arabic
- Last Verified
- 4 September 2026
Recent Developments
- Regulatory · 12 February 2026Qatar adopts Global and Domestic Minimum Tax implementing rules
Council of Ministers Resolution No. 2 of 2026, published in the Official Gazette on 12 February 2026, adopts the Rules for the Application of the Global Minimum Tax and the Domestic Minimum Top-Up Tax, implementing Qatar's OECD Pillar Two framework enacted under Law No. 22 of 2024. The rules apply to fiscal years beginning on or after 1 January 2025 and target multinational groups with consolidated revenues of at least EUR 750 million.