Law & Regulation
Law No. 22 of 2024 Amending Certain Provisions of the Income Tax Law Promulgated by Law No. 24 of 2018
The Law amends Qatar's Income Tax Law to establish the statutory basis for the Income Inclusion Rule and Domestic Minimum Top-Up Tax within Qatar's implementation of the OECD/G20 Pillar Two framework. It is a targeted international-tax amendment, not a replacement for the ordinary income-tax regime.
Legal Significance
What This Instrument Does
Inserts charging and enabling provisions for global and domestic minimum tax and connects their interpretation and application to the detailed rules subsequently issued by Council of Ministers Resolution No. 2 of 2026.
Why It Matters
A project entity may be subject to the ordinary Qatar income-tax result yet also form part of an in-scope multinational group whose jurisdictional effective tax rate and top-up-tax position must be calculated under a separate system. Contractual tax assumptions, incentives and group structuring must therefore be tested at both levels.
Key Provisions
- Relationship to Income Tax Law
The minimum-tax layer is inserted into, but analytically distinct from, the existing tax framework.
- In-scope multinational groups
Scope is group- and revenue-based, subject to detailed definitions and exclusions in the implementing rules.
- Domestic Minimum Top-Up Tax
Qatar's domestic mechanism for collecting top-up tax on low-taxed Qatar constituent entities.
- Income Inclusion Rule
Parent-entity mechanism for allocated top-up tax on relevant lower-tier entities.
- Effective-tax-rate architecture
The statutory basis for testing covered taxes against the GloBE income base by jurisdiction.
- International interpretive framework
Connection to the GloBE Model Rules, Commentary and agreed administrative guidance, as implemented in Qatar.
- Exclusions and special entities
Framework for exclusions and differentiated treatment elaborated in the Resolution.
- Administration and delegation
Authority for detailed calculation, reporting and procedural rules.
- Fiscal-year application
Application for fiscal years beginning on or after 1 January 2025, despite later Gazette publication.
- Interaction with treaties and domestic rules
Minimum tax does not eliminate ordinary income-tax, treaty or special-regime analysis.
When You Would Use This
Multinational sponsor diligence
Testing whether a sponsor group and entity fall within Pillar Two scope.
Tax modelling
Tax modelling for Qatar constituent entities.
Incentive evaluation
Evaluation of incentives or tax holidays against the minimum-tax layer.
Acquisition / restructuring analysis
Assessing Pillar Two effects of an acquisition or restructuring.
Financing covenant review
Reviewing covenants where tax liabilities affect cash.
Pillar Two compliance preparation
Preparing for registration, information returns and top-up-tax payments.
InfraLex Relevance
Large infrastructure sponsors frequently operate through multinational groups. InfraLex should explain the threshold question—whether the group and entity are in scope—before presenting project-level implications. It should not imply that every Qatar project company is subject to Pillar Two.
Legal Framework Position
- TaxAmendment
Primary / Parent Instrument
Instrument Overview
- Official Citation
- Law No. 22 of 2024
- Instrument Type
- Law / Act
- Source Language
- Arabic
- Enactment Date
- 29 December 2024
- Effective Date
- 1 January 2025
- 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.