FOR IMMEDIATE RELEASE
Pretoria 06 February, 2026
The African Tax Administration Forum (ATAF) has released its analysis of the Inclusive Framework’s Side-by-Side Package, which introduces significant changes to the Global Minimum Tax architecture, including new safe harbours, revisions to the treatment of certain tax incentives, and further simplifications. ATAF’s analysis provides an African perspective on how these developments affect the integrity of the Global Minimum Tax and their implications for domestic resource mobilisation in African countries.
Reflecting on the OECD/G20 Inclusive Framework’s agreement on the Side-by-Side Package for the modification of the Global Minimum Tax (GMT), ATAF Executive Secretary Mary Baine noted that “ATAF will unpack the implications of these rules to its members to enable them to make the necessary policy choices”. She further expressed concern on some design features of the package, especially the favourable treatment of some tax incentives, underscoring that this modification of the rules may undermine the very objectives of the GMT rules. “ATAF will continue to engage actively in further work on these rules, including the proposed stocktake process, and provide technical support to members to ensure that the implementation of these rules protects domestic revenue bases and addresses the specific concerns of African jurisdictions,” she added.
While ATAF recognises that the Side-by-Side Package seeks to accommodate different domestic tax systems and reduce compliance burdens, the analysis underscores that the core risk for African countries remains unchanged: without timely and appropriate policy responses, taxing rights over profits generated in Africa may continue to be ceded to other jurisdictions through the Income Inclusion Rule, the Undertaxed Profits Rule, or now potentially through Side-by-Side regimes. ATAF therefore reiterates the importance of protecting source-country taxing rights, in particular through well-designed and non-discriminatory Qualified Domestic Minimum Top-Up Taxes and reforms to inefficient tax incentive regimes.
ATAF welcomes elements of the package that preserve the central role of Qualifying Domestic Minimum Top-Up Taxes (QDMTT’s) and also strengthen monitoring through stocktakes and peer review, however, also cautions that expanded recognition of certain tax incentives and high substance caps may undermine revenue outcomes for African economies. ATAF will continue to support its members with technical guidance, impact assessments, and policy advice to ensure that the Global Minimum Tax evolves in a manner that is fair, balanced, and supportive of sustainable revenue mobilisation in Africa.
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Download the technical note here
For media inquiries please contact:
Nshimiyimana Fikiri
Communications Manager,
ATAF
Tel: +27738288693
Email: fikirin@ataftax.org
About ATAF
The African Tax Administration Forum (ATAF) is a platform that brings together African tax administrations to engage in mutually beneficial discussions and capacity-building initiatives. ATAF works towards promoting efficient and effective tax systems that contribute to the sustainable development of African nations.
