On 13 October 2017, the South African Revenue Service published the public notice on the submission of Country-by-Country (CbC) report, Master file, and Local file information returns under the external business requirements specification (BRS).

A Reporting Entity (other than a Surrogate Parent Entity) that is a resident of South Africa must submit a CbC Report, master file and local file within 12 months from the last day of the Reporting Fiscal Year. The submitted report should match the form and contain the information provided in the BRS.

A master file and a local file are required when the sum of a person’s potentially affected transactions for the year of evaluation (without compensating for potentially affected transactions against each other) exceeds or is reasonably expected to exceed ZAR 100M and that person is resident. The person must submit a return in the form and containing the information specified in the BRS. In that case return must be submitted within 12 months from the date on which the person’s financial year ends.

A return must be submitted electronically by using the SARS eFiling platform.