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South Africa: Country-by-country reports, final regulations

South Africa: Country-by-country reports

Regulations to implement the country-by-country (CbC) reporting requirements from the OECD’s base erosion and profit shifting (BEPS) project have been finalized in South Africa.


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The CbC draft regulations were proposed in April 2016, and were finalized on 23 December 2016. 

CbC notification requirement

A notification must be filed with the South African Revenue Service (SARS) as to whether the constituent entity of a multinational entity (MNE) group that is a resident in South Africa for tax purposes is the “ultimate parent” or the “surrogate parent entity.” If the entity is not the ultimate parent or surrogate parent entity, then details about the identity and tax residence of the reporting entity is required to be reported to SARS no later than 12 months after the last day of the reporting fiscal year of such MNE group. As of yet, there is no format or mode of such notification having been provided.

CbC reporting requirement

The final regulations state that the CbC report must contain information contained in the BEPS Action 13 final report. 

The CbC regulations in South Africa apply to years of assessment beginning on or after 1 January 2016. Therefore, for some taxpayers, the reporting year will already have commenced.


Read a January 2017 report [PDF 107 KB] prepared by the KPMG member firm in South Africa

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