Qatar Opens Pillar Two Registration Portal and Sets 30 November 2026 Deadline

Qatar’s General Tax Authority (GTA) activated its Global and Domestic Minimum Tax registration service through the Dhareeba tax platform on 2 August 2026. In-scope multinational enterprise groups must now identify their Qatari entities, appoint a designated local entity and obtain a separate Pillar Two tax identification number.

According to the official GTA announcement, groups within scope must complete their initial registration within three months after activation of the service.

Qatar’s Pillar Two legal framework

Qatar introduced its Pillar Two regime through Law No. 22 of 2024, which amended Income Tax Law No. 24 of 2018 by adding a chapter on the Global and Domestic Minimum Taxes.

The detailed implementing rules were subsequently issued through Council of Ministers Resolution No. 2 of 2026. The rules apply to fiscal years beginning on or after 1 January 2025 and establish two charging mechanisms:

-A Domestic Minimum Top-up Tax, or DMTT, for low-taxed constituent entities, joint ventures and joint-venture subsidiaries located in Qatar; and

-An Income Inclusion Rule, or IIR, under which certain Qatari parent entities may be liable for top-up tax relating to low-taxed foreign constituent entities and joint ventures.

Article 12 of Resolution No. 2 establishes the underlying registration obligation. It requires in-scope entities operating in Qatar (including joint ventures and joint-venture subsidiaries) to register through the electronic platform designated by the GTA.

Which groups must register?

The GTA’s Pillar Two Registration and Compliance Guide provides that group-based registration is required where the following conditions are satisfied:

1. The group meets the Pillar Two revenue test.
2. The group meets the MNE group test.
3. The group has a constituent entity, joint venture or joint-venture subsidiary in Qatar.
4. The group is not composed entirely of excluded entities.

The revenue test is generally met where consolidated annual revenue is at least EUR750 million in at least two of the four fiscal years preceding the tested fiscal year.

The MNE group test requires a cross-border presence. A large group operating solely in Qatar is therefore not brought within the regime merely because its revenue exceeds EUR750 million.

Conversely, registration does not depend on whether the group expects to pay top-up tax. An in-scope group must register even where:

-A transitional or permanent safe harbour may apply;

-No DMTT or IIR liability is anticipated; or

-The group intends to file its GloBE Information Return outside Qatar.

The registration obligation is determined by the group’s scope status and Qatari presence, not by the outcome of its Pillar Two calculation.

Entities operating under special Qatari regimes

Entities established or licensed in the Qatar Financial Centre, Qatar Free Zones, Qatar Science and Technology Park and Media City are not outside the registration framework merely because they operate under a special legal or tax regime.

Where such an entity forms part of an in-scope MNE group, it must be included in the group’s Pillar Two registration. Registration is completed through Dhareeba even where the entity is licensed or otherwise administered by another Qatari authority.

The Pillar Two registration is also separate from registration for corporate income tax or other Qatari taxes. An entity’s existing tax identification number does not, by itself, satisfy the Pillar Two registration requirement.

Registration is undertaken at group level

Although Resolution No. 2 refers to the registration of entities operating in Qatar, the GTA has adopted a consolidated, group-based registration model.

An MNE group generally submits one registration covering all its Qatari constituent entities. The submission is made by a designated local entity, or DLE, acting on behalf of the group.

The DLE is determined as follows:

-If the ultimate parent entity is located in Qatar, it automatically acts as the DLE unless another Qatari constituent entity is formally appointed.

-If the ultimate parent entity is outside Qatar, it must appoint one of its Qatari constituent entities as the DLE.

-If there is only one Qatari constituent entity, that entity generally becomes the DLE by default.

-An entity subject to insolvency proceedings cannot act as the DLE.

For an MNE group, the appointment must be supported by an appointment declaration issued by the ultimate parent entity or by authorised representatives of the Qatari constituent entities. The declaration must be uploaded during registration.

Where several Qatari entities could act as DLE, the choice should take account of governance, staffing, access to group information and the ability to manage continuing Pillar Two obligations. 

Responsibilities of the DLE

The DLE becomes the principal administrative representative of the MNE group in Qatar. Its responsibilities include:

-Completing the initial registration;

-Confirming or renewing the registration annually;

-Keeping registered information accurate and current;

-Providing GIR filing information or notifications where required;

-Filing the DMTT return;

-Filing the IIR return, where applicable;

-Filing the GIR locally where required;

-Paying any top-up tax;

-Maintaining supporting records; and

-Receiving and responding to GTA communications.

Groups should ensure that the appointment declaration and their internal compliance arrangements reflect these responsibilities. The appointed entity should be legally authorised and practically able to perform the role.

Joint ventures require separate registration

A qualifying joint-venture group must register separately from the principal MNE group. The joint venture and its joint-venture subsidiaries are not simply included as constituent entities in the main group registration.

A wider corporate group may consequently require:

-One registration for the principal MNE group and its Qatari constituent entities;

-A separate registration for each qualifying joint-venture group with a Qatari joint venture or joint-venture subsidiary; and

-A separate Pillar Two tax identification number for each registration.

Each joint-venture group must appoint its own DLE. According to the GTA guide, a joint-venture DLE is self-appointed and does not require an appointment declaration from its Qatari joint-venture subsidiaries.

Groups should identify joint ventures using the specific GloBE definition, including the relevant ownership and equity-accounting conditions. 

Registration deadlines

For fiscal years commencing in 2025, the GTA guide provides that the DLE must complete initial registration within three months after the GTA confirms that the electronic platform is operational.

The GTA announced the service’s activation on 2 August 2026. The resulting timetable is therefore:

Groups should also distinguish between initial registration and annual renewal. A group entering scope in a later fiscal year generally registers within six months after the end of that fiscal year. An existing registered group must review and confirm or update its registration annually within the same six-month period.

Information required for registration