The Africa Tax Administration Forum has published a technical note that breaks down the OECD's latest "Side-by-Side Package" updates to the Global Minimum Tax framework, warning African jurisdictions of potential revenue risks while urging them to adopt domestic minimum top-up taxes and to revisit their tax incentive regimes.
The Africa Tax Administration Forum (ATAF) has released a technical note on 6 February outlining changes to the Global Minimum Tax (GMT) known as the “Side-by-Side Package,” which details the package components and ATAF’s stance on related safe harbours, including the Side-by-Side safe harbour and ultimate parent entity safe harbour.
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.
Earlier, on 5 January 2026, the OECD published its Side-by-Side Package under the Pillar Two framework, providing further detail on an arrangement first discussed with the US in June 2025. The package introduces significant simplifications to the administrative and compliance requirements of the global minimum tax and proposes changes to how substance-based non-refundable tax credits are treated under Pillar Two, moving them closer in line with the treatment afforded to refundable tax credits.
