Pillar Two: Developments in South Africa’s Implementation Timeline

By Dewald Pieterse, Arno van Wyk & Neethling van Heerden

Introduction

Pillar Two, the global minimum tax initiative driven by the Organisation for Economic Co-operation Development (‘OECD’) and G20 as part of its Base Erosion and Profit Shifting (‘BEPS’) project, establishes a co-ordinated global system to ensure that large Multinational Enterprise (‘MNE’) groups, with annual consolidated turnover exceeding €750 million (in at least two out of its latest four fiscal years), pay a global minimum effective tax rate of 15% on profits arising from each jurisdiction wherein they operate. In South Africa, the Global Anti-Base Erosion (‘GloBE’) model rules have largely been incorporated into domestic law by means of the Global Minimum Tax Act 46 of 2024 and Global Minimum Tax Administration Act 47 of 2024.

Subsequent to our detailed Tax Flash on the implementation of Pillar Two in South Africa (see here), the South African Revenue Service (‘SARS’) has announced important changes in respect of the implementation timeline of Pillar Two in South Africa, which this Tax Flash is intended to highlight.

Recent developments

On 28 October 2025, the Commissioner for SARS announced[i] extensions to the deadline for notifying SARS of the identity of the entity that will be filing the GLoBE Information Returns (‘GIR’), and the deadline for the filing of the GIR itself, in respect of the fiscal year commencing on or after 1 January 2024 but before 1 January 2025.

The revised timeline is as follows:

• All notifications that would otherwise have been due before 30 April 2026, are now due no later than 30 April 2026; and
• All GIRs that would otherwise have been due before 30 June 2026, are now due no later than 30 June 2026.

SARS has also rescheduled the launch of the GloBE registration and notification functionality on its eFiling platform from December 2025 to 16 March 2026.

SARS has explained that the revised timeline is aimed at maintaining the quality, reliability and integrity of implementing Pillar Two in South Africa, with factors contributing to this adjustment including the need for thorough alignment between various technology systems and ensuring compliance with evolving international standards.

The following advances in South Africa’s implementation of Pillar Two must also be noted.

First, South Africa has signed the GIR multilateral competent authority agreement (‘MCAA’), enabling the automatic exchange of GloBE information with other jurisdictions. This reduces the administrative burden imposed on South African constituent entities by allowing for the central filing of the GIR via the ultimate parent entity or a designated filing entity.

Second, South Africa has also achieved qualified status for the domestic minimum top-up tax (‘DMTT’). Achieving qualified status reduces the risk of double taxation for affected MNE groups, because in the absence of qualified status, MNE groups faced the risk that other jurisdictions could impose their own top-up tax charges on South African profits notwithstanding South Africa having already collected its DMTT.

Contact for assistance

If you represent an MNE group with a South Arican constituent entity, or an ultimate parent entity based in South Africa, and you require any assistance in navigating the complex Pillar Two landscape, do not hesitate to reach out to us for specialised and tailored advice and assistance.

[i] See Public Notice 6763 in Government Gazette 53590.