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.