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South Africa Introduces Pillar 2 Global Minimum Tax from 2024

03 January 2025

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Approved Changes

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South Africa

South Africa Published the Global Minimum Tax Act 2024 (Act No. 46 of 2024) in the Official Gazette on 24 December 2024. The Act provides for the introduction of the Pillar 2 Global Anti-Base Erosion (GloBE) Rules in South Africa. South Africa's implementation of the rules includes an Income Inclusion Rule and a Domestic Minimum Top-up Tax. It does not include an Undertaxed Payments/Profits Rule. The Act is deemed to have come into operation on 1 January 2024 and applies to fiscal years beginning on or after that date. Note that measures for the administration of the Global Minimum Tax...