Transfer pricing and the global minimum tax in Qatar
Arm's-length documentation on a fixed timetable, and since 2025 a 15% minimum tax for the largest groups, with implementing rules published in 2026. Here is what applies and what in-scope groups must do.
Arm's length, documented
The Income Tax Law (Law No. 24 of 2018) requires transactions between related parties to be priced at arm's length and gives the GTA power to adjust profits where they are not. The documentation rules were set by GTA Decision No. 4 of 2020 on the transfer pricing declaration, Local File and Master File. Entities that meet the thresholds set by the GTA, based on revenue, assets and the value of related-party transactions, must file a transfer pricing declaration with the tax return and prepare a Local File and, where part of a group, a Master File, filed within 60 days of the corporate income tax return due date. Groups with consolidated revenue of QAR 3 billion or more are subject to country-by-country reporting.
The methods are the OECD's: comparable uncontrolled price, resale price, cost plus, transactional net margin and profit split. As elsewhere in the Gulf, the GTA's attention concentrates on intra-group services, management fees, financing and the pricing of goods moving between group companies, which also carry withholding tax consequences when paid abroad.
The 15% global minimum tax
Qatar has implemented the OECD global minimum tax. Law No. 22 of 2024, published in the Official Gazette on 27 March 2025, amended the Income Tax Law by adding Article 23 bis, which introduces an Income Inclusion Rule (IIR) and a Domestic Minimum Top-up Tax (DMTT) for fiscal years starting on or after 1 January 2025. It applies to multinational groups with consolidated revenue of EUR 750 million or more. Qatar did not adopt the Undertaxed Profits Rule.
| Step | Date |
|---|---|
| Law No. 22 of 2024 published | 27 March 2025 |
| Rules effective for fiscal years starting | 1 January 2025 |
| OECD Central Record lists Qatar's IIR and QDMTT safe harbour (transitional qualified status) | 5 January 2026 |
| Cabinet Resolution No. 2 of 2026 with detailed implementing rules published | 12 February 2026 |
| GTA opens Global and Domestic Minimum Tax registration on Dhareeba | 2 August 2026 |
| GTA Decisions Nos. 17 to 22 of 2026 on administration | 2026 |
Because Qatar's domestic top-up is recognised as qualified, other countries generally give way to it: the top-up on Qatari profits is collected in Qatar rather than by the parent's jurisdiction. For in-scope groups, that makes Qatari registration and filing a real obligation, not a formality.
Registration, calculation and records
Register on Dhareeba
In-scope constituent entities register for the Global and Domestic Minimum Tax on Dhareeba, open since August 2026, following the GTA's administrative decisions.
Compute the effective rate
Calculate the Qatar jurisdictional effective tax rate under the GloBE rules from the group's consolidated data, including exempt and special-regime entities such as free zone and QFC companies.
File and pay
File the returns and notifications within the deadlines set by the GTA; the Executive Regulations provided that no notification would be due before 30 June 2026.
Align transfer pricing
Intra-group pricing drives the Qatari effective rate. The TP Local File and the GloBE computation should tell the same story, or both will be questioned.
For a group that has historically relied on Qatari exemptions, such as GCC-owned shares, free zone holidays or the QFC's 0% route, the minimum tax changes the calculation: income that is exempt under the ordinary rules can still be topped up to 15% if the group is in scope. The exemptions remain valuable for groups below the EUR 750 million threshold, which is most foreign-owned businesses in Qatar.
Real activity behind the structure
Across the Gulf, favourable tax treatment increasingly depends on real activity: premises, qualified staff, decision-making and expenditure where the entity is registered. Qatar's special regimes, the QFC and the free zones, each set their own operating and substance expectations through licensing and reporting, and banks apply the same logic in their know-your-customer reviews. Under the minimum tax rules, substance also matters directly, because the GloBE calculation allows a carve-out from the top-up based on payroll and tangible assets in the jurisdiction.
The practical lesson is the same as in Saudi Arabia and Bahrain: a Qatari entity that is genuinely run from Qatar, with its people, premises and decisions there, is both easier to defend in a tax review and more valuable under the minimum tax rules than a nominal one.
The contents the GTA expects
The Local File is the Qatari entity's own transfer pricing report, and the GTA reads it as the first line of defence in any review. It should describe the local entity, its management and business; identify each category of related-party transaction with amounts and counterparties; set out the functional analysis of who performs which functions, owns which assets and bears which risks; explain the method chosen for each transaction and why; and present the benchmarking that shows the price falls within an arm's-length range, reconciled to the financial statements.
The Master File gives the group picture: organisation, business lines, intangibles, intercompany financing and the group's transfer pricing policies. The two must be consistent with each other, with the tax return and the transfer pricing declaration, and, for in-scope groups, with the GloBE computation. Inconsistency between these documents is what most often turns a routine request into an adjustment.
Management fees under both regimes
A Qatari subsidiary pays its European parent a management fee of QAR 3,000,000 a year. For transfer pricing, the GTA asks whether the services were actually rendered, whether they benefit the Qatari entity rather than duplicating its own management or serving the parent as shareholder, and whether the charge, typically cost plus a modest mark-up, is at arm's length. A fee that fails the benefit test is disallowed, increasing Qatari taxable profit, and the payment abroad may also attract withholding tax.
If the group is in scope of the minimum tax, the same fee now has a third dimension: by reducing Qatari profit, it lowers the Qatari jurisdictional effective rate and can trigger a domestic top-up in Qatar. A fee that is defensible for transfer pricing is normally neutral for the minimum tax; a fee that is not can create exposure under both regimes at once. Documenting the services and the benefit is therefore worth more in Qatar after 2025 than it was before.
Questions we get asked first
Does Qatar have transfer pricing documentation requirements?
Yes. Under GTA Decision No. 4 of 2020, entities that meet the GTA's thresholds file a transfer pricing declaration with the tax return and prepare a Local File and Master File, filed within 60 days of the return due date. Groups with revenue of QAR 3 billion or more file country-by-country reports.
Has Qatar implemented the global minimum tax?
Yes. Law No. 22 of 2024 introduced an Income Inclusion Rule and a Domestic Minimum Top-up Tax for fiscal years starting on or after 1 January 2025, for groups with revenue of EUR 750 million or more. Qatar did not adopt the Undertaxed Profits Rule.
What are the implementing rules for Pillar Two in Qatar?
Cabinet Resolution No. 2 of 2026, published on 12 February 2026, sets the detailed rules, and the GTA issued administrative decisions in 2026 and opened registration on Dhareeba on 2 August 2026.
Does the minimum tax affect free zone and QFC companies?
For groups in scope, yes: income exempt or taxed at a low rate under those regimes can still be topped up to an effective 15%. Groups below the EUR 750 million threshold are not affected.
What does the GTA focus on in transfer pricing reviews?
Intra-group services and management fees, financing, and the pricing of goods between related companies, often together with the withholding tax on payments abroad.
Price at arm's length, document it, and check the minimum tax
Transfer pricing in Qatar is documented on a fixed timetable, and for the largest groups the 15% minimum tax now sits on top, collected in Qatar under a recognised domestic top-up. Keep the Local File and the GloBE numbers consistent, register on Dhareeba if in scope, and build the substance that both regimes reward.
Is your group in scope?
We confirm your transfer pricing and minimum tax position in Qatar and set up the filings that follow.
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This article is general information, current as of 2026, and is not advice for any specific situation. Confirm current rules with the MOIC, the NBR or the relevant authority before acting.