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South Africa: Actions required after changes to SARS transfer pricing e-filing system

South Africa: Changes to SARS transfer pricing e-filing

The South African Revenue Service (SARS) has scheduled testing and system changes for its country-by-country (CbC) reporting electronic filing system.


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The CbC e-filing system will be switched-off from 4 December 2020 to 31 January 2021. During this period of time, e-filing will still allow for the filing of Master files and Local files.


Country-by-country (CbC) reporting was introduced in South Africa with effect for years of assessment beginning or after 1 January 2016. The responsibility for CbC reporting rests with the ultimate parent entity of a multinational group and from a South African perspective, CbC reporting applies to groups with consolidated group revenue in excess of R10 billion for the year preceding the year under review.

Because CbC reporting rules apply in many countries across the world and given international principles developed by the Organisation for Economic Cooperation and Development, a common standard for filing the reports—that are ultimately prepared for sharing between countries—has been developed. For this exchange of information, data is shared in the “XML schema” format globally, and South Africa supports the format.

Due to a global upgrade to a new version of the system, SARS is required to perform some testing and system changes; therefore, the CbC e-filing system will be switched-off for the period from 4 December 2020 to 31 January 2021. The e-filing system will still allow filing of Master files and Local files during this period. More information is available on the SARS website.

Taxpayers filing their CbC reports on the SARS system after the upgrade will need to upload XML files that are aligned with version 2.0, or they will need to make a manual submission.

Due to the system upgrade, there are new deadlines for CbC report filing for reporting fiscal years beginning before 1 March 2020:

  • With regards to a person required to file by 31 December 2020 or 31 January 2021, the deadline is extended to 28 February 2021.
  • With regards to a person required to file by 28 February 2021, the deadline is extended to 31 March 2021.

Read a November 2020 report [PDF 154 KB] prepared by the KPMG member firm in South Africa

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