The income tax treaty between Estonia and Qatar entered into force on 26 June 2026. Signed on 7 March 2024, it is the first bilateral tax treaty between the two countries.
The treaty covers Estonian income tax on the Estonian side, and Qatar income tax and corporation tax on the Qatari side.
On the question of dual residence for entities other than individuals, the treaty follows a mutual agreement approach. Where a non-individual person qualifies as a resident of both contracting states, the competent authorities of Estonia and Qatar are to determine that person's treaty residence by mutual agreement. This reflects the post-BEPS direction recommended in the OECD Model Convention, which moved away from the mechanical tie-breaker (place of effective management) that had long applied to companies.
The remaining provisions of the treaty, including the specific withholding rates, permanent establishment definition, and any special regimes applicable to Qatari sovereign wealth vehicles, are not yet publicly available in full text. Practitioners with cross-border exposure between Estonia and Qatar should obtain the treaty text directly from the Estonian Tax and Customs Board or the General Tax Authority of Qatar to assess the precise impact on their structures.