[World Tax News] Qatar Notifies New Framework for Direct Grant of Tax Treaty Benefits and More

Editorial Team – [2026] 184 taxmann.com 425 (Article)

World Tax News provides a weekly snippet of tax news from around the globe. Here is a glimpse of the tax happening in the world this week:

1. Qatar Notifies New Framework for Direct Grant of Tax Treaty Benefits

Qatar has issued Cabinet Resolution No. (4) of 2026, published in Issue 5 of the Official Gazette on 15 March 2026 (from page 95), enabling the direct application of tax treaty benefits such as reduced withholding tax rates or exemptions with effect from 16 March 2026. Earlier, Qatar followed only a refund mechanism, under which domestic withholding tax was first deducted from payments to non-residents, and eligible non-residents could subsequently claim a refund of excess tax arising from treaty relief.

Under the Resolution, resident entities may seek “approved debtor” status, which permits them to apply treaty benefits directly when making payments to non-residents. To qualify, such entities must register with the General Tax Authority (GTA), furnish details regarding their administrative, human, technical, and financial capabilities, and satisfy prescribed thresholds relating to the volume of withholding transactions or the quantum of tax withheld. Once granted, the status remains valid for three years and may be renewed upon application made at least 60 days before expiry. The status may be revoked for non-compliance, with a fresh application permitted after one year.

Where an approved debtor proposes to make a payment to a non-resident, the latter may request direct application of treaty benefits by specifying the relevant treaty provisions and confirming that it is a tax resident of the treaty jurisdiction (supported by a residency certificate), is the beneficial owner of the income, has no permanent establishment in Qatar in respect of such income, is not part of any arrangement primarily intended to obtain treaty benefits, and satisfies all other applicable treaty conditions.

The approved debtor is required to exercise due diligence in evaluating such requests and must approve or reject them within 60 days; failure to respond will be deemed a rejection, against which no appeal lies. Upon approval, the debtor must declare that it is not acting as a conduit for onward transfer of funds and undertake liability for any penalties or uncollected taxes arising from incorrect application of treaty benefits. Additionally, the approved debtor must report such payments to the GTA, including details of the nature and amount of the payment and the identity of the recipient, and furnish supporting documentation within 30 days when called upon by the GTA.

Source – Issue 5 of the Official Gazette

2. Greece Prescribes Form for Pillar Two Top-up tax Compliance

The Greek Public Revenue Authority (AADE) has issued Decision A.1055 dated 27 February 2026, which was published in the Official Gazette on 12 March 2026, approving the form and instructions for filing the Notification identifying the person responsible for submitting the Supplementary (Top-up) Tax Information Declaration.

The Notification must be filed electronically through the myAADE portal by the Greek constituent entity of an MNE group or, where more than one Greek constituent entity exists, by the locally designated entity. The filing must be made within 15 months of the end of the relevant fiscal year, extended to 18 months for the group’s first transitional year.

Source – Decision A. 1055

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