The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for South Africa on 1 January 2023.

With regard to the double taxation agreements between South Africa and other countries for which the MLI has already entered into force, the MLI is generally effective from 1 January 2023 in respect of withholding taxes and for taxable periods beginning on or after 1 July 2023 in respect of other taxes.