Qatar: Ratification of income tax treaty with UAE
Although Qatar has ratified the tax treaty, it will not become effective until the United Arab Emirates completes its own ratification procedures.
The government of Qatar on June 25, 2026, published Emiri Decree No. 39 of 2026 in the official gazette, ratifying the income tax treaty to address double taxation with the United Arab Emirates (UAE), which was signed on May 30, 2024.
Background
The tax treaty was signed on May 30, 2024, in Doha, Qatar. Although Qatar has ratified the DTT through Emiri Decree No. 39 of 2026, the income tax treaty is not yet effective because the UAE has not completed its ratification procedures. The treaty is expected to enhance tax certainty and strengthen economic cooperation between the two jurisdictions.
Summary of key provisions
The DTT would introduce the following key provisions once it becomes effective:
- Withholding tax (WHT) rates: Under the tax treaty, the source state would not have the right to apply WHT on dividends, other services, and interest, provided that the recipient is the beneficial owner of the income. Royalties and technical service fees would remain taxable in the source state but would be capped at 3% of the gross payment, representing a reduction from Qatar's domestic withholding tax rate of 5%.
- Treaty relief claims: Because Qatar generally follows a "pay and reclaim" mechanism for treaty relief claims, any withholding tax deducted by a Qatari payer on qualifying payments may be recoverable through refund procedures.
- Permanent establishment (PE): The service PE threshold would be increased from the current 183-day threshold under Qatar domestic law to 270 days. The threshold for construction and installation activities would remain 183 days.
- Other provisions: The tax treaty would include a mutual agreement procedure (MAP) allowing taxpayers to seek assistance from tax authorities to resolve cross-border disputes, as well as anti-abuse provisions to prevent inappropriate access to treaty benefits.
Read a July 2026 report prepared by the KPMG member firm in Qatar