Article 23 Bis (2), established by Law 22/2024, mandates the application of a Qualified Domestic Minimum Top-up Tax (QDMTT) on constituent entities located in Qatar, effective 1 January 2025. This rule ensures that if an entity's effective tax rate in Qatar falls below 15%, Qatar retains the right to collect the additional 'top-up' tax domestically, rather than allowing another jurisdiction to claim it under global tax rules. This provision protects Qatar's tax base while ensuring compliance with international standards for multinational corporations, maintaining the state's sovereignty over taxes generated by local operations.