Pillar Two in South Africa
South Africa has implemented OECD Pillar Two through Global Minimum Tax Act (Act No. 46 of 2024). Each applies to fiscal years beginning on or after the respective date: the IIR from 2024-01-01, the QDMTT from 2024-01-01.
Implementation Timeline
Each rule applies to fiscal years beginning on or after the date shown.
Quick reference
| Rule | Effective date | Status |
|---|---|---|
| IIR — Income Inclusion Rule | Fiscal years beginning on or after 2024-01-01 | In force OECD qualified |
| UTPR — Undertaxed Profits Rule | — | Not adopted |
| QDMTT — Qualified Domestic Minimum Top-up Tax | Fiscal years beginning on or after 2024-01-01 | Newly in force OECD qualified |
| QDMTT Safe Harbour | Available alongside the QDMTT | Case-by-case |
Implementing legislation
- Global Minimum Tax Act (Act No. 46 of 2024) — IIR + QDMTT introduction
Practical implications
MNE groups parented in South Africa are subject to the IIR for fiscal years beginning on or after 2024-01-01. Where a subsidiary's jurisdictional effective tax rate (ETR) falls below 15%, top-up tax is computed and paid in South Africa (as the jurisdiction of the parent entities), and the group must also file the GloBE Information Return (GIR).
MNE groups with constituent entities in South Africa are subject to South Africa's QDMTT for fiscal years beginning on or after 2024-01-01. Where the conditions of the QDMTT Safe Harbour are met, the IIR/UTPR computation at the parent jurisdictions may be exempted, reducing the burden of dual computation.
Recent legislative developments
- 2024: Global Minimum Tax Act (Act No. 46 of 2024) promulgated — IIR · QDMTT in force
Related terms
Try this in PillarTwo Architect
Design a group with South Africa entities together with PillarTwo Architect and see the full Pillar Two blueprint instantly.
Open the Architect → Pillar Two AboutSources
- OECD Inclusive Framework — Updated Central Record for Purposes of the Global Minimum Tax, approved 2026-05-11 (current as at 2026-05-01). OECD Global Minimum Tax
- South African Revenue Service (SARS) — South Africa Tax Authority. www.sars.gov.za
- Government Gazette — South Africa 공식 official gazette. www.gov.za
Disclaimer
This page is reference information prepared as of 2026-05-28 by synthesising the primary sources listed above, and is not legal or tax advice. Before applying any of this material in practice, please:
- Verify the latest legislation, administrative guidance, and tax authority notices
- Obtain review by a qualified Pillar Two specialist
- Reassess applicability against the specific facts and circumstances of the group
Translation note. The authoritative version of this page is the Korean original (국가별 현황 › 남아프리카공화국). This English version is provided for accessibility and may not capture every nuance of the original sources. Where precision matters, please refer to the Korean original or to the source legislation in its original language.