
ATAF Suggested Approach to Drafting Domestic Minimum Top-Up Tax Legislation
As discussions continue in the Inclusive Framework,
including the development of further administrative simplifications, additional
provisions may be added to this Suggested Approach. This is likely to include
safe harbours that will reduce the compliance burdens for both tax administrations
and taxpayers in applying the rules. These changes are anticipated to take
place in early 2023, and the Suggested Approach will be updated in light of
those safe harbours and other administrative provisions as needed.