By Antonia Nicoloudakis, Head of International Tax, PKF Octagon

Part of South Africa’s implementation of Pillar Two Model Rules (also known as Global Anti-Base Erosion (“GloBE”) or GloBE Rules), the South African Revenue Services (“SARS”) will launch the registration and notification functionality for Global Minimum Tax (“GMT”) via its eFiling platform on 16 March 2026.

Qualifying entities will be required to subscribe for GMT as a tax type on their active e-Filing profiles. The company will then be required to complete the GMT Subscription Form (RAV01).

Taxpayers Required to Complete the GMT RAV01

The RAV01 GMT section must be completed by any South African Domestic Constituent Entity (“DCE”) that forms part of a Multinational Entities Group (“MNE”) with consolidated revenue ≥ €750 million in at least two of the four preceding years.

This includes:

• South African Ultimate Parent Entity (UPE)
• South African subsidiaries of a MNE
• SA permanent establishments
• Domestic joint ventures and JV subsidiaries

Specific Information Required on the GMT RAV01

• Confirmation of legal obligation – confirmation that the entity is legally required to subscribe for GMT under the Global Minimum Tax Act
• MNE Group identification details – all MNE Group names of which the SA entity is part must be provided
• UPE information – the RAV01 requires confirmation of:
  • Whether the SA entity is itself the UPE, or
  • Whether it is a subsidiary of one or more UPEs

For each UPE listed, the following details must be captured:

Mandatory UPE fields

• Registered legal name
• Tax identification number
• Entity registration number
• Country of tax residence (country code)

• Single parented vs multi parented group status – the MNE Group needs to indicate whether the DCE is single parented or multi parented
• Selection of one UPE for filing timeline purposes – where more than one UPE exists, the SA entity must select one UPE whose fiscal year end will be used to determine notification deadlines and GIR submission deadlines under the GMT Administration Act
• Date of GMT liability – the RAV01 will require the entity to input a Date of Liability for GMT (for most groups this will be the start of the first fiscal year beginning on or after 1 January 2024, depending on the group’s year end)
• Standard RAV01 administrative information – in addition to the GMT specific fields, taxpayers must still complete or confirm the usual RAV01 data, including:
  • Bank account details
  • Contact person details
  • Physical and postal addresses
  • Registered representative details (public officer / tax practitioner)

Deadline – Timing

• SARS GMT registration and RAV01 functionality goes live on 16 March 2026
• Notification of designated local filer is due six months before the GIR deadline
• First GIR generally due 30 June 2026 for 2024 year ends

To Determine whether the GMT will affect you please consider the checklist below:

• Our group’s consolidated global revenue equals or exceeds €750 million
• Our South African entity forms part of a multinational group
• The entity is a South African company, branch, or permanent establishment
• The entity is not an excluded entity (e.g. government entity, pension fund, qualifying investment fund)

Contact your nearest PKF office if all of the above apply, as SARS registration for Global Minimum Tax is required.