ALL FAQs

Who is required to report?
The Ultimate Parent Entity (UPE) of a group must file a CbC Report return if: •it is resident of South Africa for the tax purposes; and •the total consolidated group revenue amounts to R10 billion or more for the previous Reporting Fiscal Year.

What format must the return be in?
The return must be in the format specified in the Business Requirements Specification (BRS): Country-by-Country and Financial Data Reporting. The BRS can be found on the SARS website.

Must members of MNE Groups notify SARS of who will file?
Yes, Article 3 of the CbC Regulations stipulates the notification requirements as follows: – •Any entity that is a member of an MNE Group and is resident in South Africa for tax purposes must notify SARS if it is the UPE.

Should non- residentUPEs of MNE Groups file the notifications under Article 3 of the CbC Regulations?
No, notification would not be required, since the UPE would not be a resident in South Africa.

What are the filing obligations of an entity w.r.t submission of returns for CbC Report, Master File and Local File?
The Reporting Entity (i.e. MNE Group’s UPE that is resident in South Africa or the Constituent Entity filing under Article 2(2) of the CbC Regulations) must file a CbC Report return in South Africa.

How to submit a return?
A return must be submitted electronically by using the SARS e-Filing platform.

Which e-Filing profile will be used for submissions of CbC Report returns?
An entity will continue to use its existing profiles when submitting its CBC Report return, Master and Local Files to SARS.

What type of documents can be uploaded on e-Filing for Master File and Local File returns?
The following file types may be uploaded: .pdf, .doc, .docx, .xls, .xlsx, .jpg and .gif.

What is the size- limitations pertaining to the uploading of Master File and the Local File returns?
The system will allow the specified user to upload multiple types of information (MNE Structures/Organogram, policies and financials) via e-Filing and the size of the files to be uploaded will be limited to 5 Megabytes (MB) per individual file.

What are the defined categories of Master File documents to be uploaded?
According to Annexure I to Chapter V of the Transfer pricing documentation, the following information should be included in the Master File:- • Organisational Structure (Organogram)

What are the defined categories of Local File documents to be uploaded?
According to Annexure II to Chapter V of the Transfer pricing documentation, the following information should be included in the Local File:- •Local Entity •Controlled Transactions •Financial Information

Why is the Tax Identification Number (TIN) mandatory on CbC Reporting and what should be done if an entity does not have one?
The TIN is utilised by the tax administration of the Tax Jurisdiction of the Constituent Entity. The TIN is to be mandatorily provided to ensure quality of data as well as the correct use thereof.

What currency will be used on CbC Reporting?
All amounts provided in the CbC Report should be reported, in one and the same currency, being the currency of the Reporting MNE. Reporting MNEs’ are expected to be a resident of South Africa thus, reporting in Rand.

Will the CbC Report cater for cents?
No, monetary amounts in the CbC Report return must be captured and rounded off to the nearest rand. The CbC01 Form will not allow any cents to be captured.

Last Updated: 12/02/2016 12:19 PM     print this page
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