On 31 August 2022, the South African National Assembly (NA) approved the Multilateral Convention to Implement Tax Treaty-related measures to prevent Base Erosion and Profit Shifting (MLI).  The MLI will generally enter into force for a particular covered agreement on the first day of the month following a three-month period after both parties to the covered agreement have deposited their ratification instrument.

After the Effective Date, the provisions of the MLI apply to a Covered Agreement generally from 1 January of the year following its effective date in respect of withholding taxes and for all other taxes in respect of taxable periods beginning on or after the expiration of for a period of 6 months after the Effective Date.