Qatar Issues GTA Decisions Nos. 17-22 of 2026 on Pillar Two

On 27 August 2026, Qatar published Decisions Nos. 17-22 of 2026 of the President of the General Tax Authority (“GTA”) in Official Gazette Issue No. 14 of 2026. The decisions apply to fiscal years beginning on or after 1 January 2025.

The six decisions address:

1. currency conversion;
2. transitional simplified GloBE reporting;
3. the Transitional Country-by-Country Reporting Safe Harbour;
4. simplified calculations for Non-Material Constituent Entities;
5. the appointment and responsibilities of the Designated Local Entity; and
6. registration, renewal, enforced registration and deregistration.

The new decisions implement specific powers and administrative mechanisms contained in the pre-existing legislation. 

Qatar’s domestic charging mechanisms remain the DMTT and IIR; Qatar has not introduced a domestic UTPR.

For groups whose first in-scope fiscal year began during 2025, the most immediate obligation is registration through Dhareeba. Because the registration service was activated on 2 August 2026, the initial three-month period is generally understood to expire on 2 November 2026.

1. The legislative background

Qatar’s Pillar Two framework now consists principally of three layers.

The primary legislation

Law No. 22 of 2024 amended the Income Tax Law, Law No. 24 of 2018, by adding the legislative basis for the DMTT and IIR. The legislation applies to fiscal years beginning on or after 1 January 2025.

The detailed implementing resolution

Resolution of the Council of Ministers No. 2 of 2026 contains the substantive GloBE computation and administration rules. It deals with scope, GloBE income or loss, Adjusted Covered Taxes, jurisdictional ETR calculations, the SBIE, top-up tax, reorganisations, special entities, filing, payment and transitional provisions. The GTA has published an official English version of the Resolution.

The Resolution is particularly important because it requires the Qatar rules to be interpreted consistently with the OECD GloBE Commentary and Agreed Administrative Guidance. Amendments to the Commentary and Administrative Guidance generally apply for fiscal years beginning after their approval by the Inclusive Framework, unless the Council of Ministers makes them inapplicable. Where an OECD amendment specifies another effective date, that specified date may prevail. This creates a materially dynamic relationship between Qatar law and the evolving OECD framework.

Qatar was added to the OECD Central Record with a qualified IIR and a QDMTT Safe Harbour effective from 1 January 2025. The legal consequences of qualified status include recognition of Qatar’s DMTT in the agreed Pillar Two rule order, under which a qualified domestic minimum tax generally has the first claim over low-taxed domestic income.

The GTA President’s implementing decisions

The six August 2026 decisions occupy the third layer. They exercise powers already conferred on the GTA President, particularly in relation to reporting, safe harbours, currency conversion, designated local entities and registration.

2. Decision No. 17 of 2026: currency conversion

Decision No. 17 establishes currency translation rules for the Qatar DMTT and IIR.

The governing principle is alignment with the presentation currency used in the Ultimate Parent Entity’s consolidated financial statements. This reflects the broader GloBE architecture, under which the consolidated financial statements are the starting point for the group’s computations.

The decision establishes the following exchange-rate hierarchy:

-the Qatar Central Bank rate;

-if unavailable, the European Central Bank rate; and

-if neither is available, an approved third-party source.

EUR-denominated thresholds are converted using the December average exchange rate for the calendar year preceding the beginning of the fiscal year. The final DMTT or IIR liability is converted into Qatari riyals using the fiscal year-end exchange rate for payment purposes. 

3. Decision No. 18 of 2026: transitional simplified reporting