FAQ: 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. The CbC Report, Master File and Local File returns are required for Reporting Fiscal Years commencing on or after 1st January 2016 and are due within 12 months of the year end.  The Commissioner has approved an extension for taxpayers with CbC Report returns due in December 2017 or January 2018 to submit their CbC Report returns by 28 February 2018.
  • An entity whose Potentially Affected Transactions (PAT) exceed R100 million, yet is not required to file a CbC Report return in South Africa, is required to submit a Master File return if the Ultimate Holding Company of the entity’s group is resident in South Africa or if a Master File has been be prepared by any entity within the group. A Local File return is always required from these entities.
  • The return or returns (Master and Local) must be filed for years of assessment commencing on or after 1st October 2016. First returns are due by 30 September 2018.

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