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FAQ: 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.
  • If the entity is not the UPE it must notify SARS of the identity and tax residence of the Reporting Entity.
Notification should be submitted to the following e-mail address:  [email protected]
The notifications under Article 3 are required for Reporting Fiscal Years commencing on or after 1st January 2016 and are due within 12 months of the year end. First notifications are due by 31 December 2017.

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