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.
Local filing of CbC Report returns by other members of similarly sized groups with UPEs in other jurisdictions is required in the circumstances described in Article 2(2) read with Article 2(3) of the CbC Regulations. Groups that are of this size are known as MNE Groups in the CbC Regulations.
