Qatar
Pillar Two Implementation Summary
Law/Regulations/Guidance.
§ Law No.22 of 2024 (Official Gazette, No. (8) of March 27, 2025).
Revenue Threshold. MNE groups with consolidated annual revenues equal to or exceeding €750 million in at least two of the four fiscal years preceding the relevant fiscal year.
OECD Guidelines. Generally, in line with the OECD model rules.
The rules should be interpreted and applied consistent with the GloBE model rules, commentary, and administrative guidance, including any safe harbour provisions. Any amendments to the commentary and administrative guidance will apply unless a decision is issued by the Council of Ministers excluding the application of any such amendments.
Safe Harbours.
§ Transitional CbCR Safe Harbour: Not specifically addressed; however, Law No. 22 states the rules should be interpreted and applied consistent with any OECD safe harbour provisions.
§ Transitional UTPR Safe Harbour: Not applicable, as the UTPR has not been adopted.
§ QDMTT Safe Harbour: Not specifically addressed; however, Law No. 22 states the rules should be interpreted and applied consistent with any OECD safe harbour provisions.
§ Simplified Calculations Safe Harbour (for non-material constituent entities): Not specifically addressed; however, Law No. 22 states the rules should be interpreted and applied consistent with any OECD safe harbour provisions.
De minimis Exclusion. Not specifically addressed; however, Law No. 22 states the rules should be interpreted and applied consistent with the GloBE model rules, commentary, and administrative guidance.
Initial Phase of International Activity. The exclusion is not applicable for UTPR purposes, as the UTPR has not been adopted.
Registration. Executive regulations, decisions, or circulars providing additional guidance on the application of the rules are expected to be released.
GloBE Information Return (GIR). Executive regulations, decisions, or circulars providing additional guidance on the application of the rules are expected to be released.
Notification of Filing Entity. Executive regulations, decisions, or circulars providing additional guidance on the application of the rules are expected to be released.
Penalties. The following penalties (specifically related to the provisions of Law No. 22 of 2024) may apply:
· Failure to comply with the registration and notification requirements: penalty of QAR 20,000.
· Failure to submit any declaration (i.e., DMTT or IIR tax return) within the period prescribed: penalty of QAR 500 for each day of delay, up to a maximum of QAR 180,000.
· Failure to pay the supplementary tax resulting from the application of the DMTT or the IIR within the period prescribed: penalty of 2% of the tax due for each month of delay or part thereof, not exceeding the amount of the tax due.
However, with respect to the above penalties, for fiscal years beginning on or before December 31, 2026 (and not including a fiscal year ending after June 30, 2028), transitional penalty relief may apply if the MNE group has taken reasonable measures to ensure the proper application of Law No.22 of 2024.
Additional penalties generally include:
· Failure to maintain or submit accurate and complete records or documents to the Commission within the time limit (or destruction of required documents): penalty of QAR 30,000.
· Failure to provide information or documents requested by the Commission within the specified period: penalty of QAR 200 per document not submitted, up to a maximum of QAR 72,000.
· Submitting incomplete or incorrect information to the Commission: penalty of QAR 100 for each instance, up to QAR 10,000 for each registration, declaration, notification or request on which the information is provided. Further, if proven that the missing or erroneous information led to an underpayment of tax, a taxpayer will be subject to a penalty of 50% of the tax not paid.
Effective Date. Fiscal years beginning on or after January 1, 2025.
Qualified Status of Legislation. To be determined.
Top-up Tax Return and Payment of Tax. Executive regulations, decisions, or circulars providing additional guidance on the application of the rules are expected to be released.
Penalties. The following penalties (specifically related to the provisions of Law No. 22 of 2024) may apply:
· Failure to comply with the registration and notification requirements: penalty of QAR 20,000.
· Failure to submit any declaration (i.e., DMTT or IIR tax return) within the period prescribed: penalty of QAR 500 for each day of delay, up to a maximum of QAR 180,000.
· Failure to pay the supplementary tax resulting from the application of the DMTT or the IIR within the period prescribed: penalty of 2% of the tax due for each month of delay or part thereof, not exceeding the amount of the tax due.
However, with respect to the above penalties, for fiscal years beginning on or before December 31, 2026 (and not including a fiscal year ending after June 30, 2028), transitional penalty relief may apply if the MNE group has taken reasonable measures to ensure the proper application of Law No.22 of 2024.
Additional penalties generally include:
· Failure to maintain or submit accurate and complete records or documents to the Commission within the time limit (or destruction of required documents): penalty of QAR 30,000.
· Failure to provide information or documents requested by the Commission within the specified period: penalty of QAR 200 per document not submitted, up to a maximum of QAR 72,000.
· Submitting incomplete or incorrect information to the Commission: penalty of QAR 100 for each instance, up to QAR 10,000 for each registration, declaration, notification or request on which the information is provided. Further, if proven that the missing or erroneous information led to an underpayment of tax, a taxpayer will be subject to a penalty of 50% of the tax not paid.
Qatar has not introduced the UTPR.
Effective Date. Fiscal years beginning on or after January 1, 2025.
Qualified Status of Legislation. To be determined.
Eligibility for the QDMTT Safe Harbour. To be determined.
Financial Accounting Standard. To be determined.
Top-up Tax Return and Payment of Tax. Executive regulations, decisions, or circulars providing additional guidance on the application of the rules are expected to be released.
Penalties. The following penalties (specifically related to the provisions of Law No. 22 of 2024) may apply:
· Failure to comply with the registration and notification requirements: penalty of QAR 20,000.
· Failure to submit any declaration (i.e., DMTT or IIR tax return) within the period prescribed: penalty of QAR 500 for each day of delay, up to a maximum of QAR 180,000.
· Failure to pay the supplementary tax resulting from the application of the DMTT or the IIR within the period prescribed: penalty of 2% of the tax due for each month of delay or part thereof, not exceeding the amount of the tax due.
However, with respect to the above penalties, for fiscal years beginning on or before December 31, 2026 (and not including a fiscal year ending after June 30, 2028), transitional penalty relief may apply if the MNE group has taken reasonable measures to ensure the proper application of Law No.22 of 2024.
Additional penalties generally include:
· Failure to maintain or submit accurate and complete records or documents to the Commission within the time limit (or destruction of required documents): penalty of QAR 30,000.
· Failure to provide information or documents requested by the Commission within the specified period: penalty of QAR 200 per document not submitted, up to a maximum of QAR 72,000.
· Submitting incomplete or incorrect information to the Commission: penalty of QAR 100 for each instance, up to QAR 10,000 for each registration, declaration, notification or request on which the information is provided. Further, if proven that the missing or erroneous information led to an underpayment of tax, a taxpayer will be subject to a penalty of 50% of the tax not paid.
§ Bloomberg Tax, Roadmap, OECD Pillar Two GloBE Rules – Status and Effective Dates.