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May 15, 2026

Article 23 Bis (3) requires that the Income Inclusion Rule and Domestic Minimum Top-up Tax be interpreted and applied in strict consistency with the OECD's GloBE Model Rules, Commentary, and Agreed Administrative Guidance. This includes adhering to specified rule orders and safe harbours. Any future amendments to the international Commentary or Guidance will automatically apply in Qatar unless the Council of Ministers specifically decides otherwise. This provision, effective from 2025 via Law 22/2024, ensures that Qatar's minimum tax regime remains dynamically aligned with global benchmarks and administrative practices developed by the Inclusive Framework.

SECTION 7 BIS: GLOBAL AND DOMESTIC MINIMUM TAX

Article 23 Bis (3)

The Income Inclusion Rule and the Domestic Minimum Top-up Tax referred to in the preceding two Articles must be interpreted and applied consistently with the GloBE Model Rules, the Commentary, and the Agreed Administrative Guidance, including the rule order and any Safe Harbours.

Any amendments to the Commentary, including those contained in the Agreed Administrative Guidance, for the interpretation of the GloBE Model Rules, shall apply, unless a decision is issued by the Council of Ministers to exclude the application of any of such amendments.