At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-26. Tax authority: South African Revenue Service (SARS). Summaries are simplified; check the linked official source before relying on them.
The law
#South Africa applies the arm's length principle in section 31 of the Income Tax Act 58 of 1962. It covers an affected transaction between a resident and a non-resident (or cases involving permanent establishments or controlled foreign companies) where the two sides are connected persons or associated enterprises and a term differs from what independent parties would agree. If that gives a tax benefit, the taxable income or tax of the person who gets the benefit is worked out as if the terms were arm's length (s 31(2)). The difference is treated as a deemed dividend in specie for a company, or a donation for anyone else, on the last day of the 6 months after the year of assessment (s 31(3)). That is the secondary adjustment. Section 31(5) to (7) switches the rules off for some headquarter company, controlled foreign company and long-term foreign loan cases. Associated enterprises were added to the definition of affected transaction for years of assessment starting on or after 1 January 2023 (Act 34 of 2019 s 37, as postponed by Act 23 of 2020 and Act 20 of 2021).
Documentation
#A resident whose potentially affected transactions add up to more than R100m for the year (or are expected to) must keep structure and operations records and, for each transaction above R5m, detailed transaction records (Public Notice 1334 of 2016, paras 2 to 4). The same R100m test triggers a local file, and a master file where the ultimate holding company is a South African resident or another group member has prepared a master file (Public Notice 1117 of 2017, para 2.3). Both are submitted on SARS eFiling within 12 months after the financial year end (para 3.2). CbC filers send a CbC report, master file and local file together within 12 months after the group's reporting year end (paras 2.1, 2.2 and 3.1). Records must be kept for 5 years after the return is filed (TAA s 29(3)).
Methods
#Neither section 31 nor the treaties set a required method. SARS Practice Note 7 of 1999, still listed as valid, follows the OECD Guidelines. It names the comparable uncontrolled price, resale price, cost plus, transactional net margin and profit split methods and asks for the method with the best comparability. It also says an arm's length result can be a range. The record rules in the Practice Note are replaced by Public Notice 1334. The Practice Note says there is no explicit statutory duty to keep documents, but the Notice now makes it a duty above the R100m level.
Penalties
#An understatement from a TP adjustment can bear an understatement penalty of 10% to 150% of the shortfall (TAA ss 222 and 223): 10% for a substantial understatement (above the greater of 5% of the tax or R1m), 25% for no reasonable care, 50% for no reasonable grounds for the tax position, 75% for an impermissible avoidance arrangement, 100% for gross negligence and 150% for intentional evasion. The rates rise if the taxpayer is obstructive or it is a repeat case, and fall or drop to nil with a voluntary disclosure. A fixed-amount penalty of R250 to R16,000 a month, based on taxable income, applies only to non-compliance that SARS lists in a public notice (TAA ss 210 and 211). Notice 480 of 2018 lists a missing CbC report, master file and local file from a CbC filer. It does not list the R100m master file and local file returns. For a late ITR14, SARS imposes it once a final demand has gone unanswered for 21 business days. Interest runs on unpaid tax under Chapter 12 of the TAA.
Pillar Two
#The Global Minimum Tax Act 46 of 2024 and the Global Minimum Tax Administration Act 47 of 2024 apply to fiscal years beginning on or after 1 January 2024. They give an income inclusion rule (IIR) and a domestic minimum top-up tax (DMTT). The UTPR does not apply (GMT Act s 5). The GloBE Information Return (filed on eFiling as the GMT01 return with a GMT02 declaration) is due 15 months after the fiscal year end, or 18 months for the first year, and the top-up tax is paid by the same date (GMTAA ss 3 and 5). Where a local entity or a foreign entity files for the group, each South African entity must tell SARS who files at least 6 months before that date. Public Notice 6763 moved notices for 2024-start years to 30 April 2026 and returns to 30 June 2026.
Other rules
#Weekend rule: under TAA s 244(1) a deadline that falls on a Saturday, Sunday or public holiday moves back to the last business day before it, not forward. The dates in this tool already make that move. South Africa has 12 public holidays, and a holiday that falls on a Sunday adds the Monday as a holiday (Public Holidays Act s 2(1)). The President can declare extra days, such as election day on 4 November 2026 (s 2A). The ITR14 is due 12 months after the financial year end (Public Notice 7422 for 2026). The CbC threshold is R10bn of consolidated group revenue (CbC Regulations art. 1).
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | GMT registration and notice of the entity that files the GloBE Information Return Where a designated local entity files the GIR (GMTAA s 2(3)(b)(i)), or a foreign parent or designated filing entity files it in a country with a qualifying agreement with South Africa (s 4(2)), each South African constituent entity must tell SARS who is filing at least 6 months before the GIR due date. The tool shows 9 months after the year end, or 12 months for the first year, which is 6 months before the GIR date. Public Notice 6763 moved notices for fiscal years starting in 2024 that were due before 30 April 2026 to 30 April 2026. The notice is given when the entity registers for GMT on SARS eFiling; SARS set no separate statutory date for registration. A group first liable to top-up tax in a later year also gets the 18-month GIR period (s 3(b)(ii)), so its notice is due 12 months after that year end; the tool shows the earlier 9-month date. If the date falls on a Saturday, Sunday or public holiday, it moves back to the last business day before it, and the date shown here already does that (TAA s 244(1)). A late notice can bring a penalty of up to R50,000 (GMTAA s 8). | 9 months after year end (e.g. Sep 30, 2026) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years, with a constituent entity located in South Africa (Global Minimum Tax Act s 1, GloBE Model Rules art. 1.1; SARS GMT page). | Global Minimum Tax Administration Act 47 of 2024 (GG 51884) ss 2(3)(b) and 4(2), and SARS Public Notice 6763 (GG 53590, 28 October 2025) |
| 2 | Company income tax return (ITR14) Due within 12 months from the date the financial year ends, filed on SARS eFiling (Notice 7422, paras 4(a) and 6, for financial years ending in 2026; SARS repeats the rule in an annual notice). SARS can extend the date for one taxpayer or a class by notice (TAA s 25(6) and (7)), and an extension does not move the payment date (s 25(8)). Payment of tax falls earlier through provisional tax and is not modelled here. If the date falls on a Saturday, Sunday or public holiday, it moves back to the last business day before it, and the date shown here already does that (TAA s 244(1)). A late return can bring a monthly fixed-amount penalty of R250 to R16,000 once SARS has sent a final demand and the return is still missing 21 business days later (TAA ss 210 and 211; SARS admin penalty page). This return also carries the CbC notification. | 12 months after year end (e.g. Dec 31, 2026) | Every resident company with gross income above R1,000, assets or liabilities above R1,000, a capital gain or loss above R1,000, or taxable income, taxable turnover or an assessed loss. Non-resident companies with a South African permanent establishment, South African source income or a capital gain or loss on South African assets also file (Notice 7422, para 2). | SARS Public Notice 7422 (GG 54598, 30 April 2026), income tax returns for the 2026 year of assessment, para 4(a) |
| 3 | Master file (SARS eFiling return) Due within 12 months from the date the person's financial year ends (Notice 1117, para 3.2), or 12 months from the last day of the group's reporting year for a CbC filer (para 3.1). It is submitted on SARS eFiling in the SARS reporting format (para 4). Potentially affected transactions are affected transactions without the arm's length condition in paragraph (b) of the definition, and they exclude the section 31(5) to (7) cases. The fixed-amount penalty notice (Notice 480 of 2018) covers only CbC filers; no notice was found that lists the R100m master file return, so a late R100m filing may not draw that penalty. If the date falls on a Saturday, Sunday or public holiday, it moves back to the last business day before it, and the date shown here already does that (TAA s 244(1)). | 12 months after year end (e.g. Dec 31, 2026) | A resident whose potentially affected transactions for the year exceed, or are reasonably expected to exceed, R100m, counted without netting (Notice 1117, para 2.3). A master file is needed only if the ultimate holding company is a South African resident, or another group member has prepared a master file that follows Annex I to Chapter V of the 2017 OECD Guidelines (para 2.3.1). A CbC filing entity files one with the CbC report (para 2.1 and 2.2). The tool tests transactions above R100m and cannot test the master file condition. | SARS Public Notice 1117 (GG 41186, 20 October 2017), paras 2 and 3 |
| 4 | Local file (SARS eFiling return) Due within 12 months from the date the person's financial year ends (Notice 1117, para 3.2), or 12 months from the last day of the group's reporting year for a CbC filer (para 3.1). It is submitted on SARS eFiling. The local file return draws on the records kept under Public Notice 1334: ownership and business summary, plus transaction records for each potentially affected transaction above R5m. Keeping records is a separate duty that starts at the same R100m level. The fixed-amount penalty notice (Notice 480 of 2018) covers only CbC filers, not the R100m local file. If the date falls on a Saturday, Sunday or public holiday, it moves back to the last business day before it, and the date shown here already does that (TAA s 244(1)). | 12 months after year end (e.g. Dec 31, 2026) | A resident whose potentially affected transactions for the year exceed, or are reasonably expected to exceed, R100m, counted without netting (Notice 1117, para 2.3.2). A CbC filing entity files one with the CbC report (paras 2.1 and 2.2). | SARS Public Notice 1117 (GG 41186, 20 October 2017), paras 2 and 3 |
| 5 | CbC notification (identity of the reporting entity) Due no later than 12 months after the last day of the group's reporting fiscal year (CbC Regulations art. 3). SARS says the separate email notification is no longer needed because the information is given in the ITR14 return, so in practice it goes in with the ITR14. This date follows the group's year, which may differ from the entity's own financial year; if the ITR14 is due later than this date, check with SARS how to notify on time. If the date falls on a Saturday, Sunday or public holiday, it moves back to the last business day before it, and the date shown here already does that (TAA s 244(1)). | 12 months after year end (e.g. Dec 31, 2026) | A South African resident constituent entity of an MNE group with consolidated revenue of R10bn or more in the year before the reporting year. The group's ultimate or surrogate parent says it will file. Any other resident constituent entity gives the name and tax residence of the reporting entity. Where art. 2(2) applies, the threshold is EUR 750m (CbC Regulations arts. 1 and 3). | CbC Regulations (GN R1598, GG 40516, 23 December 2016) Article 3, and SARS CbC page (ITR14 notification) |
| 6 | Country-by-country report (CbC01 on SARS eFiling) Due no later than 12 months after the last day of the reporting fiscal year, filed on eFiling (CbC Regulations art. 5; Notice 1117, paras 2.1, 2.2, 3.1 and 4). The same filer also files the master file and local file. Reporting years that began on or after 1 January 2016 are covered (art. 7). SARS extended the first deadline (GG 41306, 8 December 2017), and no extension applies now. A late or missing CbC report, master file or local file from a CbC filer draws a monthly fixed-amount penalty of R250 to R16,000 (Notice 480, GG 41621, 11 May 2018; TAA ss 210 and 211). If the date falls on a Saturday, Sunday or public holiday, it moves back to the last business day before it, and the date shown here already does that (TAA s 244(1)). | 12 months after year end (e.g. Dec 31, 2026) | The South African resident ultimate parent of an MNE group with consolidated revenue of R10bn or more in the year before the reporting year. A South African constituent entity of a foreign-parented group files only if the parent is not required to file, the parent's country has no qualifying competent authority agreement with South Africa, or SARS has told it there is a systemic failure (CbC Regulations arts. 1 and 2). | CbC Regulations (GN R1598, GG 40516, 23 December 2016) Articles 1, 2 and 5, and SARS Public Notice 480 (GG 41621, 11 May 2018) |
| 7 | GloBE Information Return (GMT01 return and GMT02 declaration on SARS eFiling) Due 15 months after the end of the fiscal year, or 18 months for the first fiscal year: the year that begins on or after 1 January 2024 and before 1 January 2025, or the first year the group owes top-up tax and has not had to file a GIR elsewhere (GMTAA s 3). Public Notice 6763 moved GIRs for 2024-start years that would fall before 30 June 2026 to 30 June 2026. For a 2025 calendar year the tool shows 31 March 2027. A group first liable in a later year gets 18 months (SARS confirms this in its GMT return guide), and the tool cannot detect that, so it shows the earlier 15-month date. One return can be filed by a designated local entity for all South African entities (s 2(2)). Records must be kept for 7 years (s 9(2)). A failure to file can bring a penalty up to R50,000, doubled if more than R5m of top-up tax is unpaid and tripled above R10m (s 8). If the date falls on a Saturday, Sunday or public holiday, it moves back to the last business day before it, and the date shown here already does that (TAA s 244(1)). | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years, with a constituent entity located in South Africa (Global Minimum Tax Act s 1, GloBE Model Rules art. 1.1; SARS GMT page). A South African entity need not file if the ultimate parent or a designated filing entity files in a country that has a qualifying competent authority agreement with South Africa for that year (GMTAA s 4). | SARS Public Notice 6763 (GG 53590, 28 October 2025) and Global Minimum Tax Administration Act s 3 |
| 8 | Top-up tax payment (income inclusion rule and domestic minimum top-up tax) The top-up tax must be paid by the GIR due date, 15 months after the fiscal year end or 18 months for the first year (GMTAA s 5(1)). A designated local entity or designated filing entity can pay for all entities (s 5(2)), and SARS can assess any one of them for the whole amount (s 5(3)). Pay with the GMT payment reference number SARS gives you. Interest follows Chapter 12 of the TAA (s 7), worked out on the daily balance and compounded monthly from 30 June 2026 (Notice 7645, GG 54921). The UTPR does not apply in South Africa (GMT Act s 5). The Act has no separate IIR or DMTT return; the GIR is the return. If the date falls on a Saturday, Sunday or public holiday, it moves back to the last business day before it, and the date shown here already does that (TAA s 244(1)). | With GloBE Information Return (GMT01 return and GMT02 declaration on SARS eFiling) (e.g. Mar 31, 2027) | South African parent entities that owe IIR top-up tax on low-taxed foreign subsidiaries (GMT Act s 4), and South African constituent entities that owe the DMTT (s 6), for fiscal years beginning on or after 1 January 2024. All South African constituent entities are jointly and severally liable for the DMTT. | Global Minimum Tax Administration Act 47 of 2024 (GG 51884), ss 2 to 5 |
| 9 | New notice when a different local filing entity is named If the group names a new designated local entity after it has already told SARS, each South African entity must give a new notice upon or immediately after the new designation (GMTAA s 2(3)(b)(ii)). There is no fixed calendar date. If the designated entity leaves the group, stops being named, or fails to file, every South African constituent entity must file the GIR itself (s 2(4)). Penalty exposure is up to R50,000 (s 8). | See note | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years, with a constituent entity located in South Africa (Global Minimum Tax Act s 1, GloBE Model Rules art. 1.1; SARS GMT page). | Global Minimum Tax Administration Act 47 of 2024 (GG 51884), ss 2 to 5 |
| 10 | GMT03 declaration (when a foreign entity files the GIR for a South African entity) SARS launched the GMT03 declaration on 21 September 2026 for South African entities whose GIR is filed abroad and exchanged with SARS. It lets SARS match the exchanged return and creates the GMT payment reference number used to pay top-up tax in South Africa. Neither the Acts nor SARS set a separate due date; SARS's guide says it works within the statutory timelines. Because top-up tax is due by the GIR date (GMTAA s 5), file the GMT03 before that date. SARS sends a Notice of Outstanding GMT03 letter if it expects one and none is filed. | See note | South African entities whose group files the GIR abroad. SARS says the South African entity may still need to file the GMT03 for local administration and payment. | SARS guide GMT-GEN-01-G02, Guide to submit Global Minimum Tax (GMT) Return on eFiling (revision 02, effective 21 September 2026) |
Official texts
#- South African Acts, public notices and regulations on transfer pricing, CbC and global minimum tax (Income Tax Act s 31, Tax Administration Act, SARS Public Notices 1117, 1334 and 6763, CbC Regulations, Global Minimum Tax Acts, Public Holidays Act) (No copyright subsists in official texts of a legislative, administrative or legal nature, or in official translations of them (Copyright Act 98 of 1978 s 12(8)(a)). Statutes, public notices and regulations may be reproduced.)