OECD Releases Side-by-Side Package for Global Minimum Tax 

The Organisation for Economic Co-operation and Development (OECD) has released a side-by-side (SbS) package for the Global Minimum Tax (GMT), covering safe harbours, Qualified Domestic Minimum Top-up Tax (QDMTT), and the future direction of global tax coordination. 

On 5 January 2026, the OECD/G20—together with 147 countries and jurisdictions participating in the Inclusive Framework (IF) on Base Erosion and Profit Shifting—published the SbS package. 

The package sets out key elements aimed at mapping the way forward for the coordinated operation of the GMT in the digital and global economy. 

Spanning 88 pages, the SbS package serves as a foundation for the international tax system, offering stability, simplicity, and certainty for Covered Taxpayers and Tax Authorities. 

Key Elements of the SbS Package of GMT 

Key features of the SbS package include the following. 

Simplified Effective Tax Rate (ETR) Safe Harbour: Under this safe harbour, the ETR of multinational enterprise (MNE) groups is determined using a simple calculation based on income and taxes reported in the group’s consolidated financial statements, with minimal adjustments. 

Extension of the Transitional Country-by-Country Reporting (CbCR) Safe Harbour: To allow more time and support a smoother transition, the IF has agreed to extend the application of the Transitional CbCR Safe Harbour by one additional year. 

Substance-based Tax Incentive Safe Harbour: This safe harbour allows MNE groups to treat qualifying tax incentives, or Qualified Tax Incentives (QTIs), as an addition when calculating Covered Taxes for constituent entities in a country or jurisdiction. 

Stocktake: The IF will conduct a comprehensive review and evidence-based objective process to ensure an equal level playing field for all IF members. This process is scheduled to be completed by 2029. 

Strengthening the Effectiveness of QDMTT: The package reaffirms QDMTT as the primary mechanism for imposing the GMT to protect domestic taxing bases in developing countries. 

Join OECD’s SbS Webinar 

The package is expected to preserve the progress achieved under the GMT framework to date and protect the ability of countries and jurisdictions, especially developing economies, to secure primary taxing rights over income generated within their territories. 

The OECD will also host a webinar on the SbS Package on 13 January 2026. Registration is available via the following link. 

https://www.oecd.org/content/oecd/en/events/2026/01/global-minimum-tax-understanding-the-side-by-side-package.html 

The full SbS package can be accessed at: 

https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/global-minimum-tax/side-by-side-package.pdf