On 11 May 2018, the South African Revenue Service (SARS) released a notice concerning penalties which provides taxpayer fails to submit returns (CbC report, Master File, Local file) by the deadline will be subject to a fixed penalty up to ZAR 16,000 per month of delay.

The penalties for non-compliance are effectively applicable not only to taxpayers who are the ” ultimate parent entity ” of an MNE group required to file a CbC report in South Africa, but also to South African taxpayers who may not be the ultimate parent of a multinational corporation but have a submission or filing obligation in South Africa.