SARS has released the Business Requirement Specification (BRS) for the Global Anti-Base Erosion (GloBE) programme, outlining how domestic constituent entities must prepare and submit XML GloBE Information Returns in line with OECD Pillar 2 rules.
The South African Revenue Service (SARS) released the Business Requirement Specification (BRS) for the Global Anti-Base Erosion (GloBE) programme on its Global Minimum Tax webpage on 13 February 2026.
This Business Requirement Specification outlines the obligations of South African domestic constituent entities to file a GloBE Information Return with SARS. It sets out the technical and procedural requirements for generating and submitting an XML data file that complies with OECD Pillar 2 standards.
This BRS describes the requirements when a Domestic Constituent Entity (DCE) has to submit a GloBE Information Return (GIR) in a data file format to SARS. A DCE will build its systems and processes according to these specifications to produce an acceptable XML datafile to provide to SARS.
Pillar 2 Model Rules (also referred to as the “Global Anti-Base Erosion” or “GloBE” Rules), released on 20 December 2021, are part of the Two Solution to address tax challenges due to economic digitalisation and was agreed with 140 member jurisdictions of the OECD / G20 Inclusive Framework on BEPS.
This project is to ensure that large Multinational Enterprises (MNEs) pay a minimum level of tax on the income arising in each jurisdiction where they operate. Taxpayers in scope calculate the effective tax rate for each jurisdiction where they operate and pay a Top-up Tax for the difference between their effective tax rate per jurisdiction and the 15% minimum rate.
Any resulting Top-up Tax is generally charged in the jurisdiction of the Ultimate Parent of the MNE. A de minimis exclusion applies where there is a relatively small amount of revenue and income in a jurisdiction.
