Article 23 Bis, introduced by Law 22/2024, incorporates OECD Pillar Two concepts into Qatari law. It defines key terms such as the 'Inclusive Framework', 'GloBE Model Rules', and 'Income Inclusion Rule (IIR)'. Crucially, it defines 'Domestic Minimum Top-up Tax', which ensures domestic excess profits are taxed at a minimum of 15%. Other definitions include Multinational Enterprise (MNE) Groups, Constituent Entities, and Safe Harbours. These definitions, effective from 1 January 2025, provide the technical foundation for Qatar's implementation of the global minimum tax regime, aligning national policy with international efforts to combat base erosion.
SECTION 7 BIS: GLOBAL AND DOMESTIC MINIMUM TAX
Article 23 Bis
In applying the provisions of this Chapter, the Executive Regulations, and the decisions issued in implementation thereof, the following terms shall have the meanings set out opposite each of them:
Inclusive Framework : The Inclusive Framework of the Organisation for Economic Co-operation and Development / Group of Twenty on Base Erosion and Profit Shifting.
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