Qatar issues implementing rules for the Global and Domestic Minimum Tax (Pillar Two)

Qatar has taken a major step in implementing the OECD/G20 Pillar Two framework (“Pillar Two” or “GloBE”) by issuing Council of Ministers Resolution No. 2 of 2026, published in the Official Gazette on 12 February 2026.

The Resolution officially adopts the Rules for the Application of the Global Minimum Tax, a top-up tax collected by Qatar in accordance with the income inclusion rules, and the Domestic Minimum Tax, also known as the Domestic Minimum Top‑Up Tax.

These rules apply to financial years starting on or after 1 January 2025.

In this Alert, our Middle East Managing Partner, Olivier Remacle, and our Tax Principal, Barbara Schwartz, describe the main provisions of the Resolution and their implications for MNE Groups operating in or maintaining constituent entities within the State of Qatar.