Qatar Issues Cabinet Resolution for Detailed IIR and QDMTT Implementation Rules

On February 12, 2026, Cabinet Resolution No. (2) of 2026, was published in the Official Gazette to provide for the detailed implementation of the IIR and QDMTT in Qatar.

This follows Law No. 22 of 2024 (issued on March 27, 2025) which implemented the Pillar Two Income Inclusion Rule (IIR) and a Domestic Minimum Top- Up Tax (DMTT which is intended to be a Qualified Domestic Minimum Top-Up Tax) from January 1, 2025.

The February 2026 Cabinet Resolution provides for the detailed application of the Pillar 2 rules in Qatar. This expressly includes the OECD Administrative Guidance as interpretive and operational sources in a number of ways:

-Interpretation rule (Article 10.1.2): the Resolution “shall be interpreted consistently with” the Commentary and any Agreed Administrative Guidance, including agreed rule order and safe harbours.

-Dynamic update rule (Article 10.2): amendments to the Commentary including through Agreed Administrative Guidance apply for fiscal years beginning after Inclusive Framework approval, unless the Council of Ministers makes them inapplicable.

-Administration rule (Article 8.3): the Authority shall apply the Resolution “in accordance with any Agreed Administrative Guidance,” subject to Article 10.2.1.

Article 11 of the Resolution provides for the application of the OECD Transitional Qualification Regime for the determination of

(i) a Qualified Domestic Minimum Top-Up Tax;

(ii) a Qualified Income Inclusion Rule;

(iii) a Qualified Under-Taxed Payment Rule;

(iv) whether a QDMTT is eligible for the Qualified Domestic Minimum Top-Up Tax Safe Harbour.

Administrative Guidance

Whilst Law No. 22 of 2024 does not include specific provisions of the OECD Administrative Guidance, Article 23 Bis (3) provides that the IIR and DMTT are to be applied and interpreted in a manner consistent with the OECD Model GloBE Rules, Commentary and Administrative Guidance.

As noted above the February 2026 Resolution supports this with Article 10.1.2 providing that the Resolution “shall be interpreted consistently with” the Commentary and any Agreed Administrative Guidance, including agreed rule order and safe harbours.

This should therefore apply all aspects of the OECD Administrative Guidance for the application of the GloBE rules in Qatar, unless specifically excluded (subject to any additional Resolutions).

The Resolution also expressly includes many aspects of the OECD Administrative Guidance including:

-Sovereign wealth funds and the definition of Ultimate Parent Entity (Article 1.4)

-Meaning of “ancillary” for Non-Profit Organisations (Article 1.6);

-Forex hedge election (Article 2.2)

-Debt release election (Article 2.4)

-Accrued pension expenses (Article 2.5)

-Excess negative tax carry-forward guidance (Article 2.7)

-Substitute Loss-carry forwards (Article 2.8 )

-Equity gain or loss inclusion election (Article 2.9)

-Allocation of taxes arising under a Blended CFC Tax Regimes (Article 2.10)