South Africa Issues Update on Pillar 2 Registration

On December 19, 2025, the South African Revenue Service issued guidance on Pillar 2 registration.

A Domestic Constituent Entity (DCE) of an in-scope MNE Group, Domestic Joint Venture or Domestic Joint Venture Subsidiary of a Domestic Joint Venture Group must register with SARS, as well as file a GloBE Information Return (GIR) with SARS in the prescribed form and format by the prescribed due date, under the GMT legislation. No prescribed date is provided yet.

The guidance confirms that SARS is planning to launch the GMT registration and notification functionality on eFiling by March 16, 2026. 

To subscribe for the GMT registration an entity will need to be a registered taxpayer. As such if an entity is not yet registered, it will need to complete the standard taxpayer registration process first. The user will then be able to request to add the new GMT tax product.

GMT Subscription Form (RAV01)

For a new GMT Subscription specific information will be required:

-Confirmation that legally the entity should be subscribed for GMT

-Note all the Multinational Enterprise (MNE) Group names that the DCE, are part of

-Confirmation if the entity is also the Ultimate Parent Entity (UPE) for one or more MNE Groups noted

-Confirmation if the specific MNE Group is Single or Multi -Parented

For all listed UPEs (and depending on the previous information) the following must be provided:

-Registered Name

-Tax Identification Number

-Entity Registration Number

-Residence Country Code

-Address Information

The DCE must select a single UPE, for which its Fiscal Year end would be used to determine the Information/Notification submission liability.

Additionally the following information are also required: bank account details, postal & physical address information.