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South Africa: Draft regulations, country-by-country reporting

South Africa: Country-by-country reporting

The South African Revenue Service (SARS) on 11 April 2016 published draft regulations concerning a country-by-country (CbC) reporting standard for multinational enterprises. This draft was issued following South Africa’s signing of a competent authority agreement for the exchange of CbC reports in January 2016.


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The draft regulations broadly appear to be in line with the OECD recommendations and set out guidance on:

  • Application
  • Filing obligation
  • A taxpayer’s duty to notify SARS
  • Information required for reporting
  • Timing
  • Rules regarding the use and confidentiality

The draft regulations state that they will apply to years of assessment commencing on or after 1 January 2016 (i.e., for some taxpayers, the reporting year will already have commenced). Comments on the draft regulations are due by 3 May 2016. 


Read an April 2016 report [PDF 79 KB] prepared by the KPMG member firm in South Africa 

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