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South Africa Introducing Pillar 2 Global Minimum Tax from 2024

01 November 2024

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Proposed Changes

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South Africa

The South African National Treasury has published the 2024 Medium Term Budget Policy Statement, along with the related bills. This includes, among others, the Global Minimum Tax Bill and the Global Minimum Tax Administration Bill, which provide 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. As drafted, the legislation will be deemed to have come into operation on 1 January 2024 and apply to fiscal years beginning on...