Implementation of Global Minimum Tax Act, 2024 and GloBE Rules

Posted 07 May 2026 Written by Acts Online
Category Tax

Brought to you by SA Legal Academy: South Africa has implemented the Global Anti-Base Erosion (GloBE) rules through the enactment of the Global Minimum Tax Act, 2024.

In terms of the Global Minimum Tax Act, 2024 and the Global Minimum Tax Administration Act, 2024, South Africa has formalised its commitment to the OECD Inclusive Framework to address base erosion and profit shifting. These Acts, which take retrospective effect from 1 January 2024, establish a 15% minimum effective tax rate (ETR) for large multinational enterprise (MNE) groups. The legislation applies specifically to MNE groups with a global consolidated annual revenue exceeding €750 million in at least two of the four fiscal years immediately preceding the tested year.

The South African Revenue Service (SARS) launched the GloBE registration portal on eFiling in March 2026. Affected entities are required to submit the first GloBE Information Return (GIR) for the 2024 fiscal year by June 2026. Failure to comply or the miscalculation of top-up tax provisions triggers administrative penalties starting at R50,000 per month, escalating to R150,000 per month for significant shortfalls.

Domestic Minimum Top-up Tax (DMTT)

South Africa has adopted a “qualified” Domestic Minimum Top-up Tax (DMTT) status, ensuring the primary taxing right remains with South Africa to collect top-up taxes on low-taxed domestic profits. If the South African ETR falls below 15%, all local constituent entities within the MNE group are held jointly and severally liable for the top-up tax. The ETR calculation is performed on an aggregate jurisdictional basis, combining the adjusted covered taxes and net GloBE income of all in-scope entities in South Africa.

Compliance and Reporting Requirements

  • The GloBE Information Return (GIR) requires the submission of over 200 specific data points per filing.
  • South Africa follows an “ambulatory approach,” meaning future OECD commentary and administrative guidance are automatically incorporated into domestic law.
  • Registration on the SARS eFiling GloBE portal is mandatory for all in-scope MNEs operating within the Republic.

What this means for you, your business, or your clients

  • For yourself: You must ensure technical proficiency in calculating jurisdictional Effective Tax Rates (ETR) and navigating the 200+ data points required for the GloBE Information Return.
  • For your business: Your firm must complete the mandatory registration on the SARS eFiling GloBE portal and prepare the 2024 fiscal year return for submission before the June 2026 deadline.
  • For your clients: You must advise multinational clients on the joint and several liability risks for South African constituent entities and the immediate impact of the 15% minimum ETR on existing domestic tax incentives.

Originally published at https://legalacademy.co.za/news/read/annual-corporate-tax-update-2026-the-globe-rules-arrive-in-south-africa

The views expressed herein are those of the author and do not necessarily reflect those of Acts Online. Acts Online accepts no responsibility for the accuracy, completeness or fairness of the article, nor does the information contained herein constitute advice, legal or otherwise.