South Africa published the Global Minimum Tax Act, 2024 (the GMT Act), in the Official Gazette on 24 December 2024.
The legislation introduces two main components: an Income Inclusion Rule and a Domestic Minimum Top-up Tax, while notably excluding an Undertaxed Payments/Profits Rule. These measures are taking effect starting 1 January 2024, applying to fiscal years that begin on or after this date.
Earlier, the South African National Treasury published its 2024 Medium Term Budget Policy Statement (MTBPS) On 30 October 2024, which included key legislative proposals such as the Global Minimum Tax Bill and the Global Minimum Tax Administration Bill. These bills aim to implement the Pillar Two Global Anti-Base Erosion (GloBE) Rules in South Africa.
