South Africa Issues a Guide to Filing Pillar Two Returns: GMT01/GMT02

On June 1, 2026, SARS external published the ‘Guide to Submit Global Minimum Tax (GMT) Returns on eFiling‘. This explains how MNE groups must access, complete, amend and support South African Global Minimum Tax filings through eFiling. 

The SARS guide addresses three key points: who must file, what must be filed, and when must South African entities act even where a return is filed centrally elsewhere.

South Africa’s Pillar Two framework

South Africa has enacted two main statutes for Pillar Two. The Global Minimum Tax Act 46 of 2024 introduces the GloBE rules into South African law and imposes top-up tax, with operation deemed from 1 January 2024 for fiscal years beginning on or after that date. The Global Minimum Tax Administration Act 47 of 2024 provides the administrative provisions for filing, payment, assessment, penalties and recordkeeping, and also applies from the commencement of the Global Minimum Tax Act.

The Global Minimum Tax Act adopts the OECD GloBE Model Rules by reference, together with the relevant Commentary, Administrative Guidance and Safe Harbours, subject to South African statutory modifications and the mechanism allowing further Inclusive Framework documents to be specified by Gazette. 

South Africa’s Pillar Two Law includes an Income Inclusion Rule and a domestic minimum top-up tax. 

Who files in South Africa: DCEs, DLEs and designated filing entities

The Administration Act starts from a local filing obligation. A domestic constituent entity, domestic joint venture or domestic joint venture subsidiary must submit a GIR, although a designated local entity may submit the GIR on behalf of all relevant South African entities. The Act also requires each domestic constituent entity to provide the designated local entity with the information needed to comply with the filing obligation.

SARS’s guide mirrors that statutory framework. It states that each constituent entity in an implementing jurisdiction must submit a GIR unless the ultimate parent entity or designated filing entity files the GIR in a jurisdiction with a qualifying competent authority agreement in effect with the local jurisdiction. It also recognises the role of a designated local entity filing for South African domestic constituent entities.

Where one South African entity files for others, the group should have clear evidence of the designation, information-sharing obligations, responsibility for sign-off, allocation of liability and a process for dealing with corrections. This is particularly important because the Administration Act preserves fallback filing obligations if no entity is designated, if the designated local entity ceases to be a member without a replacement, or if the designated local entity fails to submit.

The SARS eFiling route: registration, tax type activation and group selection

The SARS guide requires affected users to access GMT returns through eFiling. To access the GMT01 and GMT02 processes, the organisation must be registered for Global Minimum Tax, must activate GMT under tax types, and must use the relevant eFiling profile and group-management functionality. SARS has separately indicated that affected taxpayers may subscribe to and administer GMT obligations via eFiling, with the registration and notification functionality launched on 16 March 2026.

The eFiling profile should be aligned with the entity that has the statutory obligation or authority to act. 

The SARS guide also contains a practical warning on naming and group selection. When initiating GMT01, the filer must select the MNE group for the relevant period, and SARS notes that different descriptions of the same domestic constituent entity may be treated as separate selections, which can cause duplicate filings or multiple charges. 

GMT01: the South African GIR