ARTICLE · 18 MARCH 2026

South African GloBE Minimum Tax Compliance

SNG Grant Thornton

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South Africa's Global Minimum Tax (GMT) regime applies to large multi-national entity (MNE) groups with global consolidated revenues exceeding €750 million (in at least two of the four preceding fiscal years).

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Raeesa Haneef-Danka

Ellaine Raboroko

Overview of South African GloBE compliance regime

South Africa's Global Minimum Tax (GMT) regime applies to large multi-national entity (MNE) groups with global consolidated revenues exceeding €750 million (in at least two of the four preceding fiscal years).

The regime's core compliance elements are:

Determination of in-scope status based on group consolidated revenue and presence of constituent entities (i.e. any legal entity or permanent establishment that is part of a MNE Group subject to Pillar Two rules) in various jurisdictions.
Calculation of an Effective Tax Rate (ETR) on a jurisdictional basis and determining the "top-up tax" liability where the ETR is below 15%.

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