South Africa enacted the Global Minimum Tax Act, 2024 and the Global Minimum Tax Administration Act, 2024. The regime applies for fiscal years beginning on or after 1 January 2024. The rules apply to multinational groups whose consolidated annual revenue reached at least EUR 750 million in at least two of the four preceding fiscal years.
South Africa applies an Income Inclusion Rule (IIR) plus a Domestic Minimum Top-up Tax (DMTT). UTPR charging provisions are not applicable under current South African law.
Members can also download our South Africa Pillar Two Filing Checklist PDF.
The key statutory timing point is that the information / notification step falls six months before the GIR deadline. Under the Global Minimum Tax Administration Act, 2024 the GIR deadline as 18 months after year-end for the first reporting fiscal year, and 15 months after year-end thereafter.
For the first rollout, SARS published a practical implementation timetable: the registration and notification system became available on 16 March 2026; notices due before 30 April 2026 were extended to that date; and GIRs due before 30 June 2026 were extended to that date.
| Step | What SARS expects | Timing |
|---|---|---|
| GMT subscription | Add the GMT tax type on eFiling and obtain a GMT reference number. | Before filing the notification or GIR. |
| Information / notification | Tell SARS who will file the GIR for the group and, if relevant, in which jurisdiction. | 6 months before the GIR due date. |
| GIR | File by eFiling form capture or XML upload. | 18 months for the first reportable fiscal year, then 15 months. |
| Top-up tax payment | Pay any South African top-up tax by the due date under the GMTAA. | By the GIR due date under the legislation. |
SARS’ registration design is entity-by-entity. Each in-scope Domestic Constituent Entity (DCE) must register individually and will receive its own unique GMT reference number. Even if the GIR will be filed abroad and exchanged with South Africa, the South African DCE still needs to register so that SARS can identify the foreign filer and the filing jurisdiction.
A key gating item is the Registered Representative (RR). The RR must activate that status on eFiling in order to transact for the entity. The activation path is:
Organisations → SARS Registered Details → Activate Registered Representative
If the person is already the RR on SARS records, the activation is immediate. If not, the user will be prompted to upload supporting documents for verification. Once the RR is active, the RR or tax practitioner can maintain registered users and grant the relevant access rights.
The new GMT product is added through the existing entity-registration maintenance flow and the GMT subscription form on RAV01. The subscription captures, among other items:
After submission, SARS evaluates the application. The published outcomes include a notice of registration / subscription, a registration review notice, a request for supporting documents, or a rejection notice. On a successful subscription the entity receives a unique GMT reference number.
Under the GMTAA, each DCE must notify SARS of the identity of the entity that will file the GIR. That can be a South African Designated Local Entity (DLE), or a foreign Ultimate Parent Entity (UPE) or Designated Filing Entity (DFE), depending on the facts and exchange position.
Two key points are that firstly, there is no separate pre-go-live paper election for a DLE; the DLE information is supplied in the eFiling registration/notification flow. Secondly, even where the GIR will be filed in a jurisdiction that has an effective exchange arrangement with South Africa, the South African DCE still registers and notifies SARS so that SARS can determine whether it should expect the GIR from a foreign jurisdiction.
As a DCE can belong to more than one MNE group at the same time the subscription/notification design must cope with multiple groups, and the chosen UPE fiscal year-end per MNE group drives the relevant due date.
The 28 January 2026 SARS GIR business requirement specification describes two submission modes:
The BRS shows an eFiling process that includes upload or capture, a validation step, a response file, and then a declaration/commit step. In the XML route, the filer uploads the GIR XML data file, receives validation output, reviews the data, and then declares the filing so that the data is committed to the SARS database.
The same BRS also shows that a taxpayer can request the declaration again and can upload either a new file or an updated file.
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