Global Minimum Tax Publications

21 September 2026 – Global Minimum Tax: New Administration Capabilities for Affected Multinational Enterprise Groups

SARS has improved its Global Minimum Tax (GMT) administration to help affected Multinational Enterprise (MNE) Groups meet their obligations under the Global Anti-Base Erosion (GloBE) Rules. 

These improvements form part of South Africa’s commitment to international tax transparency, tax certainty, and cooperation between tax jurisdictions. The enhanced environment supports the exchange of information between participating jurisdictions; local administration of foreign submissions; payment processing; assessment administration; refunds; compliance management; and taxpayer support.  

What Is Changing? 

GMT administration is expanding beyond registration and filing to support the full compliance journey of affected MNE Groups. 

International Information Sharing 

GMT is an international tax framework that relies on participating jurisdictions sharing information about affected MNE Groups. 

SARS can now receive GMT information submitted in foreign jurisdictions and exchange information with participating tax administrations through established international exchange processes. This supports the validation of information, compliance, and the consistent application of GMT obligations across jurisdictions.  

GMT03 Declarations 

SARS has introduced the GMT03 declaration process for circumstances where GMT information is submitted by a foreign entity filing on behalf of a South African entity. 

If information has already been submitted in another jurisdiction and subsequently exchanged with SARS, a South African entity may still be required to submit a GMT03 declaration to meet local administration and payment requirements. 

GMT03 allows to SARS: 

• Recognise information received through international information-exchange processes. 
• Generate a South African GMT Payment Reference Number (PRN). 
• Administer local liabilities where applicable. 
• Support payment processing and taxpayer correspondence. 
• Validate information received from different sources. 

Payment Administration 

The updated GMT administration process introduces payment-administration capabilities linked to GMT PRNs. Where payment is required, taxpayers must use the correct GMT PRN to ensure accurate payment allocation and processing. The process also supports payment validation and administration linked to GMT obligations. 

Assessments and Compliance Administration 

The enhanced Global Minimum Tax environment introduces capabilities that support: 

• Revised assessments 
• Estimated assessments 
• Assessment notices 
• Validation outcome correspondence 
• Requests for correction and discrepancy-management processes 

When information submitted by a taxpayer differs from information received through international exchange mechanisms, SARS may issue notices or request correction before the matter can be finalised.  

Administrative Penalties 

Administrative penalties now form part of the GMT compliance framework. These processes support the administration of penalties for non-compliance with filing and notification obligations. The GMT compliance framework also supports recurring penalties where applicable, as well as established processes relating to penalty review, remission, and dispute management. 

Refund Administration 

Refund administration applies where credits arise and taxpayers request a refund. Refund requests remain subject to applicable validation, verification, and authorisation before payment can be made.  

What Affected MNE Groups Need to Do 

Affected MNE Groups should take the following actions: 

1. Review Your GMT Obligations

Determine whether your group falls within the scope of GMT and whether obligations are being fulfilled through local filing, foreign filing, or a combination of both.  

2. Understand Whether GMT03 Applies to your Organisation

If a foreign filing entity submits GMT information on behalf of a South African entity, determine whether a GMT03 declaration is required to support South African administration and payment obligations.  

3. Coordinate Internal GMT Matters Effectively

Local entities should maintain regular communication with nominated filing entities to understand and manage submissions, exchanged information, and payment obligations.

4. Monitor SARS Correspondence

Taxpayers should carefully review and respond to: 

• Acknowledgement letters 
• Validation outcome letters 
• Notices of assessment 
• Requests for correction 
• Penalty notices 
• Other GMT correspondence issued by SARS 

5. Use The Correct Payment Reference Number (PRN)

When payment is required, taxpayers must use the correct GMT PRN to avoid payment-allocation problems and delays in processing.  

6. Meet Filing, Notification, and Payment Obligations

Affected taxpayers should meet all filing, notification, and payment obligations within the applicable timeframes and should answer correspondence received from SARS promptly to avoid administrative penalties.  

What to Expect Next
SARS is committed to supporting taxpayers throughout the implementation of these requirements. Additional guidance, including detailed instructions and technical specifications, will be released to further support taxpayers and provide clarity on the practical application of the requirements.

Affected stakeholders are encouraged to consult the GMT landing page for approved guidance and frequently asked questions.

SARS looks forward to partnering with stakeholders to facilitate a smooth implementation and encourage consistent compliance among all affected taxpayers.

GMT related enquiries are managed via: [email protected]

19 December 2025 – Guide to Registering and Notifying for Global Minimum Tax

As part of South Africa’s implementation of the Global Anti-Base Erosion (GloBE) framework, the South African Revenue Service (SARS) will soon launch the registration and notification functionality for the Global Minimum Tax (GMT) via its eFiling platform. This informal guide offers early clarification and reassurance that the GMT registration and notification processes will leverage existing systems to minimise disruptions and improve compliance as it will be integrated into the familiar SARS eFiling platform.

Timeline Update

SARS has rescheduled the launch of the GMT registration and notification functionality on eFiling from December 2025 to 16 March 2026. This adjustment ensures system quality and alignment with international standards.

Registration and Subscription Process Overview

To subscribe for the GMT tax type, an entity needs to be a registered taxpayer.  If you have not yet registered, simply complete the standard taxpayer registration process first. Once that is done, you will be able to subscribe.

• CIPC Registration
  
  Often Domestic Constituent Entities (DCEs) need to be registered with the Companies and Intellectual Property Commission (CIPC). An Income Tax Reference Number is assigned automatically in this process.
• Create an eFiling Profile
  
  • Normally a DCE will access SARS eFiling by using its Income Tax Reference Number.
  • With the existing entity registration details maintenance functionality the User will request to add the new GMT tax product.
• Complete the GMT Subscription Form (RAV01)
  • For a new GMT Subscription specific information will be required:
    • Confirmation that legally you should be Subscribed for GMT
    • Note all the Multinational Enterprise (MNE) Group names that, you the DCE, are part of
    • Confirmation if you are also the/an 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) you are required to capture the appropriate information which includes:
      • Registered Name
      • Tax Identification Number
      • Entity Registration Number
      • Residence Country Code
      • Address Information

• • • To the list of UPEs provided the DCE must select a single one, for which its Fiscal Year End would be used to determine the Information/Notification submission liability per legislation.
  • General information required
    • A DCE will apply a Date of Liability
    • Additionally the following information are also completed: Bank Account-, Contact-, Postal & Physical Address information
  • Submit the form via eFiling.
• GMT Subscription Application Outcomes

  SARS will evaluate your GMT Subscription.  With a successful GMT Subscription you will be issued with a unique GMT Reference Number (account number).  Communication to you will be per the standard SARS channels and could include one of the following letters:

  • Notice of Registration/Subscription
  • Registration Review Notice
  • Request for Supporting Documents
  • Registration Application Rejection Notice

Notification Process

Under the Global Minimum Tax Administration Act (GMTAA), every DCE must notify SARS of the identity of the entity responsible for filing the GloBE Information Return (GIR).

The chosen UPE Fiscal Year End per MNE Group will be used to determine your due date for providing Information to SARS if you will be providing a GIR to SARS or not.  In the case that you will not be providing a GIR, you will need to complete the Notification portion of the Information form to let SARS know who will be providing the GIR.

What to Expect Next

SARS is committed to ensuring a smooth registration and notification experience and will provide support materials and stakeholder engagement sessions to assist taxpayers. Formal guidance, including detailed instructions and technical specifications, will be published closer to the launch date.

SARS looks forward to a collaborative implementation process with you that drives optimal compliance of all impacted Taxpayers.

For further details, refer to the guidance available:

• How do I register for tax
• How to Register for eFiling and Manage Your User Profile

Please contact our GloBE support Team at [email protected]. We appreciate your continued support and cooperation as we move forward with this important initiative.

30 October 2025 – Update on the GloBE project implementation timeline

SARS has rescheduled the launch of the GloBE registration and notification functionality on eFiling from December 2025 to 16 March 2026. This adjustment ensures system quality and compliance with international standards. For details on revised deadlines and next steps, see the below update. For queries, contact [email protected].

SARS would like to thank all stakeholders for their continued engagement and collaboration on the Global Anti-Base Erosion (GloBE) initiative. We acknowledge the significant investments and preparations made by multinational enterprise (MNE) groups in anticipation of the GloBE registration and filing process.

Following comprehensive technical reviews and project assessments, SARS wishes to inform stakeholders that the implementation of the GloBE registration and notification functionality on eFiling has been rescheduled from December 2025 to 16 March 2026.

This revised timeline is necessary to maintain the quality and reliability expected of this significant initiative. Factors contributing to this adjustment include the need for thorough alignment between various technology systems and ensuring compliance with evolving international standards. These considerations are crucial for safeguarding both the integrity of the GloBE solution and the interests of all parties involved. Section 3(b) of the Global Minimum Tax Administration Act, 2024 (GMTAA) provides that the due date for the submission of the GloBE Information Return (“GIR”) for a Reporting Fiscal Year beginning on or after 1 January 2024, is the date that is 18 months after the end of the 2024 Fiscal Year (for subsequent Fiscal Years it will be 15 months). In cases where the MNE Group’s Fiscal Year ended before 31 December 2024 due to a change in Fiscal Year, a takeover by another MNE Group or the like, this would mean that GIRs must be submitted before 30 June 2026.

Section 2(3)(b) of the GMTAA requires Domestic Constituent Entity (DCE) to notify the Commissioner no later than six months prior to the filing due date of the GIR of the identity of the Designated Local Entity (DLE) that will file the GIR. Similarly, section 4(2) of the GMTA requires the notification of the Ultimate Parent Entity (UPE) or Designated Filing Entity (DFE) that will file the GIR and the jurisdiction in which it is located. This is for SARS to determine ahead of time if there is a Qualifying Competent Authority Agreement in place with the jurisdiction from which the GIR will be received. Essentially the DCEs may appoint a DLE, UPE or DFE as their agent to file the GIR.

An extension under section 25(7) of the Tax Administration Act, 2011 (TAA) is proposed for the following:

• Notifications that would be due before 30 April 2026, to 30 April 2026; and
• For GIRs that would be due before 30 June 2026, to 30 June 2026. It is important to note that this is primarily aimed at the registration and notification process. The submission of the GIR is extended only for those MNE Groups whose Fiscal Year concludes before 31 December 2024, meaning that in cases where GIRs would have been due prior to 30 June 2026, the submission deadline is now extended to 30 June 2026.

In our effort to reduce compliance challenges and ensure the effective implementation of the
GloBE framework, SARS notes two significant positive developments in South Africa’s adoption of the GloBE framework:

• South Africa has signed the GloBE Information Return Multilateral Competent
  Authority Agreement (MCAA), enabling the automatic exchange of GloBE
  information with other jurisdictions.
• South Africa has achieved qualified status for the Domestic Minimum Top-Up Tax, reducing the risk of double taxation for affected MNE Groups.

We acknowledge that this adjustment may require some stakeholders to revise internal project plans. We apologise for any inconvenience this may cause and assure you that SARS remains committed to open communication and transparency throughout this process. Further guidance will be issued closer to the March implementation date, including system readiness updates and taxpayer testing timelines.

Thank you for your continued cooperation and understanding as we work together to ensure a high-quality, stable, and internationally compliant GloBE platform. We urge Stakeholders to continue their internal preparations for filing, system integration, and readiness testing as planned.

Please contact our GloBE support team at [email protected]. We
appreciate your continued support and cooperation as we move forward with this
initiative.

28 October 2025 – Extension of the due date for notices and the due date for GLOBE Information Returns

Tax Administration Act, 2011: Public Notice 6763 of Government Gazette 53590 of 28 October 2025, published in terms of section 25(7), extending the due date for notices and the due date for GLOBE Information Returns for the Fiscal Year commencing on or after 1 January 2024 but before 1 January 2025.

12 September 2025 – SARS Gears Up for Pillar Two GloBE Model Rules

On October 8, 2021, the Organisation for Economic Co-operation and Development (OECD) introduced the Global Anti-Base Erosion (GloBE) Model Rules under the Pillar Two initiative. These are model rules agreed by the Base Erosion and Profit Shifting (BEPS) Inclusive Framework to establish a global minimum tax framework for large multinational enterprises (MNEs) to ensure that they pay a minimum level of tax on their income in respect of every jurisdiction where they operate.

In alignment with this initiative, South Africa enacted the GloBE minimum tax (GMT) legislation, which comprises the Global Minimum Tax Act, 2024 (GMTA) enacted on 24 December 2024, and the Global Minimum Tax Administration Act, 2024 (GMTAA) enacted on 9 January 2025. These Acts are administrated by the Commissioner, deemed to come into operation on 1 January 2024 and applies to “fiscal years” (the accounting period used in the consolidated financial statements of in-scope MNEs) beginning on or after that date.

The purpose of implementing the GloBE Model Rules in South Africa in the GMT legislation is to enable South Africa to impose a multinational top-up tax at a rate of 15 per cent on the excess profits of in-scope MNE Groups. The GloBE Rules apply to MNE Groups whose consolidated annual revenues in at least two of the four preceding fiscal years equal or exceed EUR 750 million. The multinational top-up tax under the GMT legislation is imposed under—

• An Income Inclusion Rule (IIR) which taxes the domestic constituent entity of an MNE Group on its allocable share of Top-up Tax arising in respect of the low-taxed income of any foreign group company in which it has a direct or indirect ownership interest; and
• A Domestic Minimum Top-Up Tax (DMTT) which imposes a joint and several tax liability on the domestic constituent entities of an MNE Group for any top-up tax arising in respect of low-taxed income of these entities (calculated on an aggregate basis but only with respect to the entities located in South Africa).

The registration and reporting obligations Domestic Constituent Entity of in-scope MNEs in terms of the GMTAA, is as follows:

• 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.
• Where a “designated local entity” is appointed by one or more DCEs required to file a GIR, each of the DCEs that appointed the designated local entity must notify SARS of the identity of the designated local entity that will file on its behalf
• The DCEs must submit the notice no later than six months prior to the filing due date of the GIR. This due date is 15 or 18 months after the end of the reportable fiscal year for which the GIR must be filed (for the 2024 fiscal year or the first fiscal year that the GIR must be filed by a DCE, this period is 18 months). For example, the notifications in respect of the 2024 fiscal year must be filed before 31 December 2025 (assuming the fiscal year is a calendar year)
• File the first GIR no later than eighteen months after the end of the first reportable fiscal year. For example, for the 2024 reportable fiscal year the GIR must be filed before 30 June 2026 (assuming a calendar year)
• File the second and subsequent GIR no later than fifteen months after the end of the second and following reportable fiscal years.

SARS Readiness

SARS is actively preparing to administer the GloBE framework. A dedicated project team, including IT and system engineers, has been established to integrate GloBE procedures and forms into the existing eFiling system. This integration will create a centralised platform for registration, notifications and return submissions.

Furthermore, a specialised unit within SARS’s Large Business & International Unit is being capacitated, involving both newly recruited and existing staff, to oversee the implementation of the GMT legislation. This unit collaborates closely with the National Treasury and other key SARS internal stakeholders, such as the Legislative Policy Tax, Customs and Excise Unit and the Exchange of Information Unit.

Voluntary Compliance

SARS promotes voluntary compliance and seeks to simplify adherence with the GMT legislation. To support taxpayers, SARS is developing a portal to host all GloBE-related information to ensure that all stakeholders are well-informed, and taxpayers are supported. SARS encourages all affected stakeholders to stay informed about the GMT legislation and the applicable GloBE model rules, commentary, and administrative guidance to facilitate a smooth implementation process.

More information on the GMT legislation can be found here Acts Administered by the Commissioner | South African Revenue Service and Explanatory Memoranda | South African Revenue Service.

More information on the GloBE framework can be found here on the OECD website.

Please contact our GloBE support Team at [email protected].

We appreciate your continued support and cooperation as we move forward with this important initiative.