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Global Minimum Tax: New Administration Capabilities for Affected Multinational Enterprise Groups

Global Minimum Tax: New Administration Capabilities for Affected Multinational Enterprise Groups

21 September 2026 – 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.

  1. 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.

  1. 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.

  1. 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
  1. 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.

  1. 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]