South Africa: Updated legislation implementing Pillar Two global minimum tax rules submitted to Parliament
The government submitted legislation to implement the OECD’s Pillar Two GloBE model rules.
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November 20, 2024
The South African government on October 30, 2024, submitted to the National Assembly legislation to implement the OECD’s Pillar Two global anti-base erosion (GloBE) model rules.
- Administration: The bill has been updated and now defines the GloBE Information Return (GIR) to include both a GIR in an international context and an information return for domestic minimum top-up tax purposes, which are both required to be submitted to the South African Revenue Service within 15 months after the end of the reporting fiscal year (18 months for the transitional year), subject to certain exceptions.
- Penalties: As proposed initially, a non-compliance penalty of ZAR 50,000 (approximately €2,600) would be applied per month per constituent entity. In addition, under the updated law the amount of the penalty would double if the top-up tax not paid exceeds ZAR 5 million (approximately €261,000) and would triple if the top-up tax due exceeds ZAR 10 million (approximately €521,000).
Read a November 2024 report prepared by KPMG's EU Tax Centre