South Africa Issues a Government Notice to Extend Certain Pillar 2 Filing Deadlines

On October 28, 2025, Government Notice No. 6763 was issued which extended some of the Pillar 2 filing and notification deadlines.

Designated Local Entity

Every Constituent Entity located in South Africa has an obligation to file a GloBE Information Return (GIR) in South Africa. However, under Section 2(2) of the GMT Administration Act this obligation can be discharged if the GIR is filed by a Designated Local Entity.

Where the GIR is being filed by the Designated Local Entity, the Constituent Entity, must file a notification with the Tax Authority no later than six months prior to the filing due date of the GIR. Government Notice No. 6763 of October 28, 2025 provides that for Fiscal Years commencing on or after January 1, 2024 but before January 1, 2025, this date is extended to April 30, 2026.

This impacts MNE Group’s with a December 31, 2024 year end, as the initial notification for the transition year would have been due by 31 December 2025 (6 months prior to the transitional GIR filing due on June 30, 2026).

The notification must contain all information necessary for the correct application of the Top-Up Tax.

Designated Filing Entity

Section 4 of the GMT Administration Act also provides that a Domestic Constituent Entity need not submit the GIR if the tax authority is notified that the return has been submitted by:

– the UPE located in a jurisdiction that has a Qualifying Competent Authority Agreement in effect with South Africa for the reporting fiscal year; or

– a Designated Filing Entity located in a jurisdiction that has a Qualifying Competent Authority Agreement in effect with South Africa for the reporting fiscal year.

Again, a Domestic Constituent Entity must notify the tax authority of the identity of the entity that submits the GIR and the jurisdiction in which it is located within six months prior to the filing due date of the GIR.  Government Notice No. 6763 of October 28, 2025 provides that for Fiscal Years commencing on or after January 1, 2024 but before January 1, 2025, this date is also extended to April 30, 2026.

GIR Filing

The GIR must be filed no later than 15 months after the end of the fiscal year (with an 18-month deadline for the Transition Year – but not before June 30, 2026).