GTL Summary:

Article 23 Bis (7) establishes severe penalties for non-compliance with the global and domestic minimum tax regime, effective 2025. Delays in submitting specific returns incur 500 QAR daily fines (up to 180,000 QAR). Late payment of Top-up Tax triggers a 2% monthly penalty. Violating registration or notification rules results in a 20,000 QAR fine. However, Law 22/2024 includes a transitional period (financial years ending by June 2028) where penalties may be waived if the MNE Group demonstrates 'reasonable measures' and good faith in system establishment. Tax evasion or fraud cases are excluded from this transitional leniency.

Document Type: Tax Law Article
Law: Income Tax Law 24 of 2018
Article Number: 23-bis-7
Country: 🇶🇦 Qatar
Location: Section 7 Bis - Global and Domestic Minimum Tax
Order: 40
Last updated at: 2026-02-23 12:13:40 UTC

SECTION 7 BIS: GLOBAL AND DOMESTIC MINIMUM TAX

Article 23 Bis (7) [G36]

Subject to the provisions of Article 24 of this Law and the decisions issued in application of Article 34 thereof, the President or his delegate shall impose a financial penalty in the cases stipulated in the following clauses:

  1. Any taxpayer who fails to submit the returns stipulated in this Chapter within the period prescribed in accordance with the decision of the Council of Ministers provided for in Article 23 Bis (5) of this Law, shall be subject to a financial penalty of five hundred (500) Riyals for each day of delay, up to a maximum of one hundred and eighty thousand (180,000) Riyals.

  2. Any taxpayer who fails to pay the Top-up Tax arising from the application of the Income Inclusion Rule or the application of the Domestic Minimum Top-up Tax within the period prescribed in the decision of the Council of Ministers provided for in Article 23 Bis (5) of this Law, shall be subject to a financial penalty of (2%) two percent of the amount of tax due for each month of delay or part thereof, not to exceed the amount of tax due.

  3. Any taxpayer who violates the registration and notification provisions stipulated in this Chapter and the decision of the Council of Ministers provided for in Article 23 Bis (5) of this Law, shall be subject to a financial penalty of twenty thousand (20,0000) Riyals. The concerned party shall be notified of the financial penalties imposed, in accordance with what is specified by the Regulations.

GTL Notes

[G36]Article added as per Law No. (22) of 2024. Effective from 1 January 2025.

Article 4 of Law No. (22) of 2024 provides the following:

  1. The financial penalties stipulated in Article 23 Bis (7) of the aforementioned Income Tax Law shall be waived during the transitional period, if it is determined that the MNE Group has taken reasonable measures to ensure the proper application of Chapter Seven Bis of the aforementioned Income Tax Law.

  2. The Authority shall consider that an MNE Group has taken reasonable measures within the meaning of the first paragraph of this Article if the MNE Group demonstrates that it has, in good faith, established appropriate systems to understand and comply with the GloBE Model Rules and the rules related to the Qualified Domestic Minimum Top-up Tax.

  3. The Authority must assess whether the MNE Group has met the standard of taking reasonable measures based on the facts and circumstances of the case.

  4. For the purposes of applying the first and second paragraphs of this Article, the transitional period means any financial year beginning on or before 31 December 2026, and does not include a financial year that ends after 30 June 2028.

  5. Anyone who commits any act of tax evasion, avoidance, or fraud shall not benefit from the provision of the first paragraph of this Article.

  6. The MNE Group must correct any errors committed and pay any Top-up Tax that has not been paid in whole or in part.

  7. The Authority shall issue the necessary circulars and guidance manuals for the application of this Article.

←
Previous
Article 23 Bis (6)
Next
Article 23 Bis (8)
→
Fast-loading version for search engines - Click here for the interactive version