Introduces an income inclusion rule (IIR) and a domestic minimum top-up tax (DMTT) for fiscal years starting from January 1, 2025
Law No. 22 of 2024, published in the Official Gazette on March 27, 2025, introduces an income inclusion rule (IIR) and a domestic minimum top-up tax (DMTT) for fiscal years starting from January 1, 2025. This legislation aligns with the OECD Model Rules but does not include the undertaxed payments rule (UTPR).
The new rules will be interpreted and applied according to the OECD Model Rules, Commentary, and Administrative Guidance, including safe harbour provisions. While safe harbours are not specifically introduced, transitional penalty relief is included.
The legislation states that the minimum tax provisions will apply despite any conflicting rules, potentially affecting entities benefiting from preferential tax regimes like the Qatar Financial Centre, Qatar Science and Technology Park, or Qatar free zones.
Penalties for non-compliance include a QAR500 (approximately €130) daily penalty for delayed IIR and DMTT returns, capped at QAR180,000 (approximately €46,000), a 2% monthly penalty for late payment of top-up tax, and various penalties for registration, filing, and record-keeping failures.
Further details are anticipated in upcoming Executive Regulations.
Read an April 2025 report prepared by KPMG’s EU Tax Centre