South Africa’s Revenue Service had expanded its Global Minimum Tax (GMT) administration to support affected Multinational Enterprise (MNE) Groups with registration, filing, payment, assessment, compliance and refund obligations.
South Africa’s South African Revenue Service (SARS) had enhanced its Global Minimum Tax (GMT) administration to support affected Multinational Enterprise (MNE) Groups in meeting their Pillar Two obligations under the Global Anti-Base Erosion (GloBE) Rules.
The improvements, announced on 21 September 2026, had expanded GMT administration beyond registration and filing to cover international information sharing, local administration of foreign submissions, payment processing, assessments, refunds, compliance management and taxpayer support.
International information sharing
GMT is an international tax framework that relies on participating jurisdictions sharing information concerning affected MNE Groups.
SARS can now receive GMT information submitted in foreign jurisdictions and exchange information with participating tax administrations through established international exchange processes. The arrangements support the validation of information, compliance and consistent application of GMT obligations across jurisdictions.
GMT03 declarations
SARS had introduced the GMT03 declaration process for circumstances where GMT information is submitted by a foreign entity filing on behalf of a South African entity.
Where information has already been submitted in another jurisdiction and subsequently exchanged with SARS, a South African entity may still be required to submit a GMT03 declaration to meet local administration and payment requirements.
GMT03 allows SARS to:
- Recognise information received through international information-exchange processes.
- Generate a South African GMT Payment Reference Number (PRN).
- Administer local liabilities where applicable.
- Support payment processing and taxpayer correspondence.
- Validate information received from different sources.
Payment and assessment administration
The updated GMT administration process introduces payment-administration capabilities linked to GMT PRNs. Where payment is required, taxpayers must use the correct GMT PRN to ensure accurate payment allocation and processing.
The process also supports payment validation and administration linked to GMT obligations.
The enhanced Global Minimum Tax environment also supports revised assessments, estimated assessments, assessment notices, validation outcome correspondence, and requests for correction and discrepancy-management processes.
Where information submitted by a taxpayer differs from information received through international exchange mechanisms, SARS may issue notices or request correction before the matter can be finalised.
Administrative penalties and refunds
Administrative penalties now form part of the GMT compliance framework. The processes support the administration of penalties for non-compliance with filing and notification obligations.
The GMT compliance framework also supports recurring penalties where applicable, together with established processes relating to penalty review, remission and dispute management.
Refund administration applies where credits arise and taxpayers request a refund. Refund requests remain subject to applicable validation, verification and authorisation before payment can be made.
Actions for affected MNE Groups
Affected MNE Groups should determine whether their group falls within the scope of GMT and whether obligations are being fulfilled through local filing, foreign filing or a combination of both.
Where a foreign filing entity submits GMT information on behalf of a South African entity, organisations should determine whether a GMT03 declaration is required to support South African administration and payment obligations.
Local entities should maintain regular communication with nominated filing entities to understand and manage submissions, exchanged information and payment obligations.
Taxpayers should also review and respond to SARS correspondence, including acknowledgement letters, validation outcome letters, notices of assessment, requests for correction, penalty notices and other GMT correspondence issued by SARS.
Where payment is required, taxpayers must use the correct GMT PRN to avoid payment-allocation problems and delays in processing.
Affected taxpayers should meet all filing, notification and payment obligations within the applicable timeframes and answer correspondence received from SARS promptly to avoid administrative penalties.
Further guidance
SARS said additional guidance, including detailed instructions and technical specifications, would be released to support taxpayers and provide clarity on the practical application of the requirements.
Affected stakeholders had been directed to the GMT landing page for approved guidance and frequently asked questions.
GMT-related enquiries are managed via LBqueries.Globe@sars.gov.za.
