Extension prescribed in filing of Globe information

By Associate Professor David Warneke, Head of Income Tax Technical

On 28 October 2025 the Commissioner of SARS prescribed extensions to the due dates for the filing of notifications due under the Global Minimum Tax Administration Act (Act 47 of 2024). Importantly, these extensions will apply to notifications that, depending on the financial year end in question, may otherwise have had to be filed before 30 April 2026 - in many cases the notifications would have had to be filed by 31 December 2025 - by Multinational Groups that are within scope of the Global Minimum Tax Act. 

Broadly, Multinational Groups that fall within the scope of the Global Minimum Tax Act include at least one Entity or Permanent Establishment that is not located in the jurisdiction of the ultimate Parent Entity and have an annual revenue of EUR 750 million or more in the Consolidated Financial Statements of the Ultimate Parent Entity in at least two of the four Fiscal Years immediately preceding the tested Fiscal Year. 

This extension comes as a welcome breather to affected Multinational Groups, courtesy of the lack of readiness of SARS’ systems to receive and process the notifications.

The GloBE rules are also referred to as the Pillar Two Model Rules. They were released in December 2021 as part of the “Two-Pillar Solution” to address challenges due to economic digitalization, and were agreed with some 140 member jurisdictions of the Organisation for Economic Co-operation and Development’s (OECD’s) Inclusive Framework on Base Erosion and Profit Shifting. The Project seeks to ensure that large MNEs pay a minimum level of income tax in each jurisdiction in which they operate.

The two notifications affected are the Notices under section 2(3)(b)(i) or section 4(2) of the Global Minimum Tax Administration Act. 

The Notice under section 2(3)(b)(i) is a notification to the Commissioner, no later than six months prior to the filing due date of the GloBE Information Return, of the identity of the Entity that is submitting the GloBE Information Return. The Notice must be filed by each Domestic Constituent Entity of an MNE Group unless one of the Domestic Constituent Entities has been appointed by the other Domestic Constituent Entities to submit the GloBE Information Return on their behalf, in which case the Notice has to be filed by such appointed entity (the Designated Local Entity). However, if the GloBE Information Return is submitted by an Ultimate Parent Entity of the MNE Group or a Designated Filing Entity that is located in a jurisdiction that has a Qualifying Competent Authority Agreement in effect with South Africa for the Reporting Fiscal Year. Domestic Constituent Entities of the MNE Group do not have to submit the GloBE Information Return to the Commissioner. In this case, in terms of section 4(2) of the Global Minimum Tax Administration Act, the Domestic Constituent Entities must notify the Commissioner, no later than six months prior to the filing due date of the GloBE Information Return, of the identity of the Entity that submits the GloBE Information Return and the jurisdiction in which it is located.

The concept is that the information contained in the GloBE Information Return will automatically be shared by revenue authorities that have Competent Authority Agreements in place with each other relating to the sharing of GloBE information. Therefore, if the GloBE Information Return is filed in a jurisdiction with which South Africa has such an Agreement in place, it should not be necessary to file it in South Africa as well. As of 5 November 2025, the following were signatories to the Multinational Competent Authority Agreement on the exchange of GloBE information: Austria, Belgium, Denmark, Finland, France, Germany, Hungary, Ireland, Italy, Japan, Korea, Liechtenstein, Luxembourg, the Netherlands, New Zealand, Norway, Portugal, the Slovak Republic, South Africa, Spain, Switzerland and the United Kingdom.

Where the above Notices are due prior to 30 April 2026, the due date for filing the Notices has been extended to 30 April 2026. Since the first Fiscal Year to which the Global Minimum Tax Act applies is the Fiscal Year that commenced on or after 1 January 2024 and the due date for the submission of the first GloBE Information Return is 18 months after the end of the 2024 Fiscal Year, the due date of the filing of the first GloBE Information Return of a Domestic Constituent Entity for its Fiscal Year ended 31 December 2024, barring a change in this date because of an event such as a change in Fiscal Year, is 30 June 2026. Since the above Notices are due no later than six months prior to the due date of the Global Information Return, the due date for the filing of either Notice would have been 31 December 2025. The extension granted by the Commissioner on 28 October 2025 is to 30 April 2026, where the Notice in question is due before 30 April 2026. Thus, the extension will also apply to Domestic Constituent Entities that had Fiscal Years that ended on 31 January 2025, 28 February 2025 and 31 March 2025, among others.

Extension has also been granted for the submission of GloBE Information Returns that may have been due before 30 June 2026, to 30 June 2026. A GloBE Information Return may become due prior to 30 June 2026 because of a change in Fiscal Year, among other possibilities.

SARS envisages that Domestic Constituent Entities will have to use eFiling to register and subscribe with SARS for the Global Minimum Tax functionality.

A template for the GloBE Information Return is still under development by SARS. It is an onerous document that will contain, among other things:

• information on the Constituent Entities, including their tax identification numbers, the jurisdiction in which they are located and their status under the GloBE Rules;
• information on the overall corporate structure of the MNE Group including the Controlling Interests in the Constituent Entities held by other Constituent Entities; and
• the information necessary to compute:
  • the Effective Tax Rate for each jurisdiction and the Top-up Tax of each Constituent 
    Entity;
  • the allocation of the additional tax amounts payable to each jurisdiction; and 
  • a record of the elections made in accordance with the relevant provisions of the GloBE Rules.

Failure to comply with the requirement to file the Notices or the GloBE Information Return lead to the imposition of penalties under the Global Minimum Tax Administration Act.

The GloBE Rules impose onerous requirements on MNE’s that are within scope. The extensions granted by SARS are both sensible and will be widely welcomed, given the lack of readiness of SARS documentation, systems and processes to support the required disclosures.