South Africa’s Global Minimum Tax (GMT) regime applies to large multi-national entity (MNE) groups with global consolidated revenues exceeding €750 million (in at least two of the four preceding fiscal years).
The regime’s core compliance elements are:
- Determination of in-scope status based on group consolidated revenue and presence of constituent entities (i.e. any legal entity or permanent establishment that is part of a MNE Group subject to Pillar Two rules) in various jurisdictions.
- Calculation of an Effective Tax Rate (ETR) on a jurisdictional basis and determining the “top-up tax” liability where the ETR is below 15%.
- GloBE Information Returns (GIRs) and/or notifications to SARS under local administrative rules.
South Africa’s regime includes an Income Inclusion Rule (IIR) and a Domestic Minimum Top-Up Tax (DMTT) and specifically excludes the application of the Undertaxed Payments Rule (UTPR) under local law.
When the South African company is the Ultimate Parent Entity (UPE) of the global MNE
If a South African entity is the Ultimate Parent Entity (UPE) (i.e. the top-level controlling company of the MNE group and not controlled by any other group entity) the following elements should be considered:
When the South African company is a subsidiary / Constituent Entity of a foreign UPE
If the South African company is not the UPE, but rather a constituent entity of an MNE group whose UPE is located in another jurisdiction:
Safe Harbours
South Africa’s GMT legislation incorporates the OECD Pillar Two safe harbour mechanisms, which may significantly reduce compliance and calculation burdens for qualifying MNE groups.
Safe harbours do not remove registration or notification obligations, but they may eliminate or simplify the detailed top-up tax calculation for a jurisdiction. There are two types of safe harbour mechanisms adopted:
- The Transitional CbCR Safe Harbour - a short-term measure that would effectively exclude an MNE’s operations in certain lower-risk jurisdictions from the scope of GloBE in the initial years, thereby providing relief to MNEs in respect of their GloBE compliance obligations as they implement the rules.
- The Permanent Safe Harbour that would reduce the number of computations and adjustments an MNE is required to make under the GloBE Rules or allow the MNE to undertake alternative calculations to demonstrate that no GloBE tax liability arises with respect to a jurisdiction.
Transitional extensions granted by SARS SARS has provided the following blanket extensions:
- Notifications due before 30 April 2026 → extended to 30 April 2026.
- GIRs due before 30 June 2026 → extended to 30 June 2026.
The SARS External Business Requirement Specification on GMT provides the following GMT information/notification scenarios:
| SC | DCE | MNE Group | FYE of UPE(MM/DD) | Inf./Notif.Identifier No. | Inf./Notif.Identifier due before |
Inf./Notif.Identifier sent 3 months prior |
GIR due before | Start date of Reporting FYE | End date of Reporting FYE |
|---|---|---|---|---|---|---|---|---|---|
|
1
|
DCE1
|
MNE1
|
31-Jan
|
MNE1-2975
|
31-Jan-26
|
31-Oct-25
|
31-Jul-26
|
1-Feb-24
|
31-Jan-25
|
|
2
|
DCE2
|
MNE2
|
30-Apr
|
MNE2-964
|
30-Apr-26
|
31-Jan-25
|
31-Oct-26
|
1-May-24
|
30-Apr-25
|
|
2
|
DCE2
|
MNE3
|
31-Oct
|
MNE3-790
|
31-Oct-26
|
31-Jul-25
|
30-Apr-27
|
1-Nov-24
|
31-Oct-25
|
|
3
|
DCE3
|
MNE4
|
1-Jan
|
MNE4-7713
|
1-Jan-26
|
1-Oct-25
|
1-Jul-26
|
2-Jan-24
|
1-Jan-25
|
| SC | DCE | MNE Group | FYE of UPE(MM/DD) | Inf./Notif.Identifier No. | Inf./Notif.Identifier due before |
Inf./Notif.Identifier sent 3 months prior |
GIR due before | Start date of Reporting FYE | End date of Reporting FYE |
|---|---|---|---|---|---|---|---|---|---|
|
1
|
DCE1
|
MNE1
|
31-Jan
|
MNE1-2975
|
31-Oct-26
|
31-Jul-26
|
30-Apr-27
|
1-Feb-25
|
31-Jan-26
|
|
2
|
DCE2
|
MNE2
|
30-Apr
|
MNE2-964
|
31-Jan-26
|
31-Oct-26
|
31-Jul-27
|
1-May-25
|
30-Apr-26
|
|
2
|
DCE2
|
MNE3
|
31-Oct
|
MNE3-790
|
31-Jul-26
|
30-Apr-27
|
30-Apr-27
|
1-Nov-25
|
31-Oct-26
|
|
3
|
DCE3
|
MNE4
|
1-Jan
|
MNE4-7713
|
1-Oct-26
|
1-Jul-26
|
1-Apr-27
|
2-Jan-25
|
1-Jan-26
|
Overview of South African GloBE compliance regime
South Africa’s Global Minimum Tax (GMT) regime applies to large multi-national entity (MNE) groups with global consolidated revenues exceeding €750 million (in at least two of the four preceding fiscal years).