SARS postponed the GloBE registration and notification launch on e-Filing, granting extensions to ease compliance for affected MNE Groups.
The South African Revenue Service (SARS) has rescheduled the launch of the GloBE registration and notification functionality on e-Filing from December 2025 to 16 March 2026. This adjustment ensures system quality and compliance with international standards.
This announcement was made on 30 October 2025.
This revised timeline is necessary to maintain the quality and reliability expected of this significant initiative. Factors contributing to this adjustment include the need for thorough alignment between various technology systems and ensuring compliance with evolving international standards.
These considerations are crucial for safeguarding both the integrity of the GloBE solution and the interests of all parties involved. Section 3(b) of the Global Minimum Tax Administration Act, 2024 (GMTAA) provides that the due date for the submission of the GloBE Information Return (“GIR”) for a Reporting Fiscal Year beginning on or after 1 January 2024, is the date that is 18 months after the end of the 2024 Fiscal Year (for subsequent Fiscal Years it will be 15 months).
In cases where the MNE Group’s Fiscal Year ended before 31 December 2024 due to a change in Fiscal Year, a takeover by another MNE Group or the like, this would mean that GIRs must be submitted before 30 June 2026.
Section 2(3)(b) of the GMTAA requires Domestic Constituent Entity (DCE) to notify the Commissioner no later than six months prior to the filing due date of the GIR of the identity of the Designated Local Entity (DLE) that will file the GIR.
Similarly, section 4(2) of the GMTA requires the notification of the Ultimate Parent Entity (UPE) or Designated Filing Entity (DFE) that will file the GIR and the jurisdiction in which it is located. This is for SARS to determine ahead of time if there is a Qualifying Competent Authority Agreement in place with the jurisdiction from which the GIR will be received. Essentially the DCEs may appoint a DLE, UPE or DFE as their agent to file the GIR.
An extension under section 25(7) of the Tax Administration Act, 2011 (TAA) is proposed for the following:
- Notifications that would be due before 30 April 2026, to 30 April 2026; and
- For GIRs that would be due before 30 June 2026, to 30 June 2026. It is important to note that this is primarily aimed at the registration and notification process. The submission of the GIR is extended only for those MNE Groups whose Fiscal Year concludes before 31 December 2024.
In their effort to reduce compliance challenges and ensure the effective implementation of the
GloBE framework, SARS notes two significant positive developments in South Africa’s adoption of the GloBE framework:
- South Africa has signed the GloBE Information Return Multilateral Competent Authority Agreement (MCAA), enabling the automatic exchange of GloBE information with other jurisdictions.
South Africa has achieved qualified status for the Domestic Minimum Top-Up Tax, reducing the risk of double taxation for affected MNE Groups.
