Changes to the Global Minimum Tax: The ‘Side-By-Side Package

Abstract

This Technical Note summarises the January 2026 updates to the Global Minimum Tax framework under the Inclusive Framework’s “Side-by-Side Package,” outlining key design changes and their implications for jurisdictions. It explains the introduction of new safe harbours, revisions to the treatment of certain tax incentives, and administrative simplifications aimed at easing compliance while preserving the integrity of the minimum tax system. The note also highlights ATAF’s perspectives on the reforms—particularly the risks of revenue loss, the importance of implementing domestic minimum top-up taxes, and the need to reassess tax incentive regimes. Overall, it positions the reforms as both a policy and administrative turning point, with ATAF providing guidance and technical support to help African members safeguard their tax bases and strengthen domestic resource mobilisation.