Free zone holiday and Pillar Two

Does our QFZ tax holiday protect us from top-up tax?

The situation

The Pillar Two law overrides conflicting domestic measures, so free zone entities may be in scope.

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
  • Qatar Free Zones regime (QFZA): 100 percent foreign ownership and a tax holiday of up to 20 years on QFZA terms

What it means for you

Include QFZ entities in the Qatar effective tax rate calculation. A holiday that gives 0 percent can create a top-up close to 15 percent of excess profit for an in scope group. Weigh this before relying on the holiday in group planning.

What to do

  1. Include QFZ entity.
  2. Compute ETR.
  3. Model top-up.
  4. Review holiday value.

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

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