Upon a bit of further investigation, it's interesting to note that btrfs
snapshots preserve ownership (i.e. btrfsctl -S test / --> test is owned
by root:root just like /)

So, one workaround is the policy invariant "Any directories where a
confined process can write to should only be granted owner read
permissions", though this is a pretty subpar workaround...

Even in a fairly restricted  apparmor profile, as long as inherit-
execute permissions are available to the btrfsctl binary,and write
permissions exist to the snapshot destination, btrfs snapshotting will
succeed. No further AA capabilities are required, which is a bit
concerning.

-- 
Too easy to circumvent AppArmor using btrfs snapshots
https://bugs.launchpad.net/bugs/484786
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