TaxSavvyQA

Exempt Qatari share and top-up tax

Our Qatar profits are mostly exempt as Qatari owned. Could we owe top-up tax?

The situation

DMTT tops up tax in Qatar to 15 percent where the Qatar effective rate is lower.

The law

  • Law No. 22 of 2024 amending Law No. 24 of 2018 (global minimum tax): IIR and DMTT at 15 percent for MNE groups with EUR 750 million revenue in two of the four prior years, for years from 1 January 2025
  • Law No. 24 of 2018 and GTA filing rules for Qatari and GCC owned entities: The share of profit owned by Qatari and GCC nationals is exempt, but the entity still files

What it means for you

Exempt profit lowers the Qatar ETR. If an in scope group pays 3 percent on QAR 200 million Qatar profit, the top-up before carve outs is about 12 percent of excess profit. Model this early.

What to do

  1. Compute Qatar ETR.
  2. Apply substance carve out.
  3. Estimate DMTT.
  4. Plan cash.

We can do this for youPillar Two scoping, DMTT and IIR readiness for groups with Qatar entities: QAR 18,000

Related