GMT Newsflash
As you may know, as of 16 March 2026, SARS activated the Global Minimum Tax (GMT) registration feature on eFiling, which means there is now a registration obligation for certain taxpayers regardless of whether they are the ultimate reporting entity or have a top-up tax liability.
Specifically, each South African Domestic Constituent Entity (DCE) within a Multination Entity (MNE) Group must register if their group has consolidated revenue of at least EUR 750 million in at least two of the four preceding fiscal years. South African DCEs include:
- South African Ultimate Parent Entities (UPEs);
- Subsidiaries of foreign-headquartered MNEs;
- Permanent establishments of foreign entities; and
- Certain joint ventures.
Registration involves each DCE registering for GMT on SARS eFiling. It is important to note that this requirement stands even if no top-up tax applies or if another group entity will file the GloBE Information Return (GIR) on their behalf.
Compliance requirements
The specific compliance requirements relating to GMT in South Africa has been summarised below.
Registration
An in-scope MNE must apply for registration to SARS for the GMT Tax Product on eFiling by 30 April 2026.
Notification submission
- DCEs must submit the notification at least six months before its filing deadline, which is 15 or 18 months after the end of the relevant fiscal year (for 2024 or a DCE’s first GIR, the period is 18 months).
- If a designated local entity is appointed to file the GIR, all appointing DCEs must notify SARS of that entity’s identity.
- A designated local entity is not needed if the UPE is foreign headquartered and will be filing the GIR in a different jurisdiction that has a Qualifying Competent Authority Agreement with South Africa.
- For MNE groups with a fiscal year ending 31 December 2024, the deadline to file the notification is 30 April 2026.
GIR submission
- The first GIR is due for submission within 18 months after the end of the initial reportable fiscal year. For MNE groups with a fiscal year ending 31 December 2024, the deadline to file the GIR is 30 June 2026.
- Subsequent GIRs are due within 15 months following each later reportable fiscal year.
- If an MNE becomes liable for top-up tax only after 2024, it has 18 months to file its first GIR and fifteen months for each following year.
Further information can be found on the SARS website here:
Please let us know if you have any questions or require any further assistance in this regard. We are able to assist with the GMT registration and notification submission.