Action Required for Multinational Groups With South African Operations
South Africa has formally implemented the Organisation for Economic Co-operation and Development (OECD) Pillar Two Global Minimum Tax (GloBE) rules and has activated the compliance framework through the South African Revenue Service (SARS). With registration and notification functionality live as of March 2026 and critical deadlines approaching in April and June, multinational enterprise (MNE) groups with South African constituent entities should consider taking immediate action.
Who Is Affected?
South Africa’s Pillar Two rules apply to MNE groups that:
- Have consolidated annual revenue of at least €750 million in at least two of the prior four fiscal years; and
- Have South African constituent entities, including subsidiaries, branches, or permanent establishments.
The rules apply for fiscal years beginning on or after January 1, 2024.
Registration Now Live on SARS eFiling
SARS launched its Global Minimum Tax (GMT) registration and notification functionality on its eFiling platform on March 16, 2026.
- South African constituent entities must register and subscribe for the GMT tax product via SARS eFiling.
- Registration must be performed via the RAV01 “Maintain SARS Registered Details” process on eFiling by the entity’s Registered Representative with the appropriate eFiling access. Groups that have not set up a SARS Registered Representative should do so before attempting to subscribe.
- After subscribing, the GMT tax type must be activated on the entity’s eFiling profile (under “Manage Tax Types”) to enable subsequent return and notification submissions.
- Groups that have not confirmed eFiling access (for example, ensuring the entity’s tax reference is active in an eFiling profile) should do so immediately to avoid delays.
Mandatory Notification Deadline
Each South African constituent entity (domestic constituent entity, DCE) of an in‑scope MNE group is required to notify SARS of the entity that will file the GloBE Information Return (GIR).
The notification must identify:
- The reporting entity that will submit the GIR, e.g., the ultimate parent entity, a designated filing entity, or a designated local entity; and
- The jurisdiction in which that entity is located.
This notification requirement applies to every DCE, even if the GIR will be filed outside South Africa under a centralized or designated filing arrangement. For the transition year (fiscal years beginning on or after January 1, 2024, but before January 1, 2025) SARS has extended the notification deadline to April 30, 2026.
Failing to submit the notification by this date may expose South African entities to compliance risk and potential penalties.
GloBE Information Return Filing Deadline
For MNE groups with fiscal years ending on or before December 31, 2024, the first GIR must be submitted by June 30, 2026 (18 months after the end of the 2024 fiscal year, consistent with South Africa’s adoption of the OECD transition timeline).
South Africa participates in the Multilateral Competent Authority Agreement (MCAA), allowing GIRs to be filed centrally in another jurisdiction, provided the required South African notification has been submitted on time.
Qualified Domestic Minimum Top-up Tax
South Africa has enacted a Qualified Domestic Minimum Top‑Up Tax (QDMTT) that has received “qualified” status under the OECD Inclusive Framework peer review process. An important clarification:
- No separate South African QDMTT return is currently required (the SARS GMT registration/notification guide and systems include no standalone QDMTT form or filing requirement).
- At this stage, compliance is satisfied through the GIR filing, with no additional local return.
Key Dates at a Glance
- March 16, 2026 – GMT registration and notification opens on SARS eFiling.
- April 30, 2026 – Deadline to notify SARS of the GIR filing entity (for FY 2024 transition year).
- June 30, 2026 – Deadline to submit first GIR (for MNE groups with fiscal years ending on or before December 31, 2024).
What Should Groups Be Doing Now?
Affected groups may consider the following steps:
- Confirm whether South African entities are in scope under Pillar Two (meet the €750M threshold and ownership criteria).
- Confirm SARS eFiling access and a registered representative are in place for each in-scope entity (set up and activate eFiling profiles as needed).
- Determine who will file the GIR (ultimate parent entity, designated filing entity, or local filer) for the group.
- Prepare and submit the mandatory SARS notification by April 30, 2026 (via the GMT Notification on eFiling).
- Begin compiling data for the GIR due June 30, 2026, including calculations of GloBE income, covered taxes, and any top-up tax due.
How Forvis Mazars Can Help
Forvis Mazars can assist multinational groups with South Africa Pillar Two scoping and impact assessments, registration and notification support on SARS eFiling, GIR preparation and coordination with global filing strategies, as well as integration of South Africa into broader Pillar Two compliance frameworks. If you would like to discuss how these requirements apply to your group or need assistance meeting the upcoming deadlines, please contact a Forvis Mazars professional today.