Executive summary

Qatar has published the first package of implementing decisions supporting the country's Global and Domestic Minimum Tax framework. The package consists of six decisions issued by the President of the General Tax Authority (GTA), published in Issue No. 14 of the Official Gazette on 27 August 2026. The decisions supplement Council of Ministers' Resolution No. (2) of 2026 and provide practical guidance on the administration and operation of Qatar's Pillar Two framework. (See EY Global Tax Alert, Qatar amends provisions of Income Tax Law No. (24) of 2018 to introduce DMTT and IIR, dated 27 March 2025.)

The published decisions address several key areas necessary for implementation, including (1) currency conversion rules, (2) simplified reporting procedures, (3) the transitional Country-by-Country Reporting (CbCR) Safe Harbour, (4) simplified calculations for non-material constituent entities, (5) appointment of a Designated Local Entity and (6) registration requirements. The framework applies to fiscal years beginning on or after 1 January 2025.

The release of these decisions represents an important step in Qatar's transition from a legislative Pillar Two framework to an operational compliance regime. The guidance provides affected multinational enterprise groups (MNE Groups) with greater clarity regarding reporting obligations, registration procedures, safe harbor eligibility and compliance responsibilities under the Global and Domestic Minimum Tax provisions.

Detailed discussion

Currency conversion rules

Decision No. (17) of 2026 establishes detailed rules relating to currency conversion for Global Anti-Base Erosion (GloBE) calculations and Domestic Minimum Top-up Tax (DMTT) purposes. The decision clarifies that GloBE calculations are generally performed using the presentation currency of the group's consolidated financial statements. It also prescribes rules for converting top-up tax liabilities into Qatari riyals and sets out the methodology for converting monetary thresholds into euros when determining whether a group falls within scope.

The decision further provides guidance on the use of exchange rates, including the use of Qatar Central Bank reference rates and alternative sources when necessary.

Transitional simplified reporting procedures

Decision No. (18) of 2026 introduces a Transitional Simplified Jurisdictional Reporting Framework. The framework applies to fiscal years beginning on or before 31 December 2028, provided the fiscal year does not end after 30 June 2030.

The framework allows qualifying MNE Groups to simplify certain jurisdictional reporting obligations where no top-up tax arises or where top-up tax does not require constituent entity-level allocation. However, groups must maintain reliable accounting systems, contemporaneous supporting documentation and allocation methodologies, and the GTA retains the authority to request additional information and perform compliance reviews.

Transitional CbCR Safe Harbour

Decision No. (19) of 2026 introduces the Transitional CbCR Safe Harbour, which may deem top-up tax for a jurisdiction to be zero when specified conditions are met during the transition period.

To this effect, the decision establishes three alternative tests:

1. A de minimis test based on revenue and profit thresholds
2. A simplified effective tax rate test
3. A routine profits test based on the substance-based income exclusion.

The decision also includes detailed provisions relating to hybrid arbitrage arrangements, permanent establishments, investment entities, joint ventures and other special cases that may affect safe harbor eligibility.

Additionally, the transition period, which was extended in January 2026, includes fiscal years commencing on or before 31 December 2027, but excludes fiscal years with an end date beyond 30 June 2029.

The transition rate is 16% for fiscal years beginning in 2025 and 17% for fiscal years beginning in 2026 and 2027.

Simplified calculations for nonmaterial constituent entities

Decision No. (20) of 2026 introduces a permanent simplification mechanism for nonmaterial constituent entities. A filing constituent entity may elect annually to use simplified calculations when determining GloBE income, revenue and adjusted covered taxes for eligible entities.

The decision aims to reduce administrative costs by allowing reliance on specified CbCR figures and simplified tax calculations for qualifying entities.

Designated Local Entity framework

Decision No. (21) of 2026 establishes the framework for appointing a Designated Local Entity (DLE). The decision clarifies the requirement for MNE Groups and joint venture groups to appoint a DLE. The DLE acts as the principal compliance entity for the MNE Group in Qatar and is responsible for filing the GloBE Information Return, submitting required notifications, filing top-up tax returns, and paying taxes and penalties.

The decision outlines appointment requirements, annual confirmation obligations, data-access requirements and procedures relating to changes, replacement and disqualification of a DLE. It also requires that the DLE have unrestricted access to relevant financial and tax information necessary to fulfil its obligations.

Registration requirements

Decision No. (22) of 2026 sets out registration, amendment and deregistration procedures for in-scope MNE Groups and joint venture groups. These groups must complete registration through the GTA's designated electronic platform, which requires extensive information regarding the Ultimate Parent Entity, the DLE, constituent entities, joint venture subsidiaries, ownership structures and reporting periods.

For fiscal years beginning in 2025, initial registration must be completed within three months from the date the GTA announces that the electronic platform is operational. Thereafter, registrations must be confirmed or updated annually within six months after the end of the relevant fiscal year.

Implications

The publication of the six decisions provides important practical guidance for the implementation of Qatar's Global and Domestic Minimum Tax framework and signals the beginning of the operational compliance phase for Pillar Two in Qatar. In-scope MNE Groups should review the new requirements and assess their readiness to comply with the registration, reporting and payment obligations introduced by the decisions.

Businesses should evaluate their eligibility for the transitional reporting simplifications, CbCR Safe Harbour provisions and simplified calculation mechanisms for nonmaterial constituent entities, as these measures may significantly simplify compliance during the transition period.

Groups with operations in Qatar should also determine which entity should be appointed as their DLE, establish appropriate governance and reporting processes, confirm access to the necessary financial and tax data, and prepare for registration through the GTA's electronic platform once operational. Early assessment and implementation efforts should help reduce compliance issues and facilitate timely adherence to Qatar's Pillar Two requirements.