The Global Minimum Tax (“GMT”) is part of the Organisation for Economic Cooperation and Development’s (”OECD’”) Pillar Two initiative. Its goal is simple: to make sure that the world’s largest multinational groups pay at least 15% corporate tax in every country where they operate. This prevents groups from shifting profits into low-tax jurisdictions and helps level the playing field globally.
South Africa introduced the Global Minimum Tax Administration Act, 2024 (“GMTAA”) to bring these rules into local law. On 12 September 2025, the South African Revenue Service (“SARS”) issued new guidance on compliance, deadlines, and filing.
Who is Affected?
The rules apply to multinational enterprise (“MNE”) groups with annual global revenues of at least EUR 750 million.
In South Africa, the focus is on what are called Domestic Constituent Entities (“DCE”s). A DCE is simply any South African company or branch that belongs to one of these large multinational groups. For example, if a global group headquartered in Europe with EUR 1 billion in revenue has a subsidiary in Johannesburg, that South African subsidiary is a DCE and must comply with the GMT rules.
The law also extends to domestic joint ventures (“JV”s) and their subsidiaries if they form part of an in-scope group.
Key Compliance Requirements
Registration & Filing
Every DCE must register with SARS. Each DCE is then required to file a GloBE (Global Anti-Base Erosion) Information Return (”GIR”). The GIR is a standardised return designed under the OECD framework. It collects detailed information about the multinational group’s global profits, taxes paid, and effective tax rates. This is the main tool that allows SARS (and other tax authorities worldwide) to check whether the group has met the 15% minimum tax.
To simplify compliance, the group may choose one South African company to act as the designated local filer. This company will take responsibility for submitting the GIR on behalf of all the group’s South African entities. If a designated filer is appointed, the other South African group companies must notify SARS of this arrangement.
Notification Deadlines
Notification to SARS about the designated local filer must be made at least six months before the GIR is due. For multinational groups with a 2024 calendar year-end, this means the notification deadline is 31 December 2025.
Filing Deadlines
- First GIR filing: Due 18 months after the end of the group’s first reportable year.
- For a 2024 year-end, this is 30 June 2026.
- Subsequent GIR filings: Due 15 months after the end of each fiscal year.
Why This Matters for Business
- New compliance layer: Large groups must track global tax data in a way that aligns with the OECD’s GloBE rules.
- Tight timelines: With the first notification due by 31 December 2025 and the first GIR filing by 30 June 2026, preparation cannot be left until the last minute.
- Risk of penalties: Missing deadlines or providing incomplete returns could result in financial penalties and extra scrutiny from SARS.
- Action required now: MNE groups should begin setting up systems for collecting the required information, identifying who will act as the designated local filer, and ensuring governance processes are in place.
In Summary
South Africa has now stepped firmly into the Global Minimum Tax era. If your multinational group earns more than EUR 750 million, your South African operations will need to register, notify SARS, and prepare to file a GloBE Information Return (GIR).
The first key deadline is 31 December 2025 for notifications, followed by the first GIR filing on 30 June 2026.This is a major shift in corporate taxation and compliance. Now is the time to prepare.
If you’d like to discuss how these changes may affect your group’s South African operations, please get in touch with us.
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