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On 24 December 2024, the Global Minimum Tax Act, Act No. 46 of 2024, was promulgated in South Africa. This Act introduced the GloBE (“Global Anti-Base Erosion”) Rules as set out by the Organisation for Economic Cooperation and Development (“OECD”). The GloBE Rules aim to ensure that large multinational enterprises (“MNEs”) pay a minimum level of tax on income arising in each jurisdiction where they operate, addressing the tax challenges posed by the digital economy.
Subsequently, on 09 January 2025, the Global Minimum Tax Administration Act, Act No. 47 of 2024 (“GMTAA”), was enacted and is administered by the South African Revenue Service (“SARS”). This Act outlines the administrative requirements for South African entities that form part of an MNE Group, including Domestic Constituent Entities, Domestic Joint Ventures, and Domestic Joint Venture Subsidiaries.
Filing and notification requirements
Under the GMTAA, affected entities must submit a GloBE Information Return to the Commissioner. Furthermore, these entities are required to notify SARS, no later than six months prior to the GloBE Information Return’s filing due date, of the identity of the entity responsible for submitting the Return.
The due dates for filing the GloBE Information Return are as follows:
- 15 months after the end of the Fiscal Year; or
- 18 months after the end of the Fiscal Year, if it is the first Fiscal Year commencing on or after 1 January 2024 but before 1 January 2025, or if the MNE Group is liable to the Top-up Tax and has not previously been required to submit a GloBE Information Return in another jurisdiction for a prior Fiscal Year (excluding Fiscal Years before 1 January 2024).
Given the effective date of the legislation, this would mean that a company with a tax year ending 31 December 2024, would be required to file an initial notification by 31 December 2025 and the GloBE Information Return would ordinarily be due by 30 June 2026.
Current status of SARS guidance
As of the date of this article, SARS has not released any specific information or guidance regarding the process for filing the initial notification or the GloBE Information Return. This lack of guidance, coupled with the approaching deadlines, has created significant pressure for taxpayers attempting to meet compliance requirements under the new legislation.
Extension of filing deadlines
Recognising the challenges faced by taxpayers, SARS issued an extension notice on 28 October 2025. The extension applies to entities with fiscal years commencing on or after 1 January 2024 but before 1 January 2025, as follows:
If the required notification was due before 30 April 2026, the deadline is now extended to 30 April 2026.
If the GloBE Information Return was due before 30 June 2026, the deadline is now extended to 30 June 2026.
Recommendation and next steps
Although SARS has extended the filing deadlines, it remains advisable for affected entities to begin preparing the required notifications and GloBE Information Returns as soon as possible. Early preparation will help ensure compliance and reduce the risk of last-minute complications, especially given the absence of formal guidance from SARS at this stage.
We will continue to monitor developments and will notify you immediately upon the release of further information from SARS regarding the format and process for filing the required documentation.
Conclusion
The introduction of the Global Minimum Tax Act and Administration Act marks a significant shift in South Africa’s approach to taxing multinational enterprises. While the recent extensions granted by SARS provide temporary relief, proactive compliance planning is essential. Please contact us should you require further assistance in navigating these new requirements or have any queries regarding your entity’s obligations.
