South Africa has introduced two bills to parliament aimed at implementing the OECD’s global minimum tax rules. These bills align with the OECD’s plan to reform international taxation and set a minimal company tax fee of 15% for multinationals incomes over €750 million ($815 million) yearly, known as Pillar Two. The legislation includes an income inclusion rule that adds a top-up rate for companies paying below the 15% threshold in any jurisdiction. Additionally, a domestic top-up tax will apply in South Africa to ensure compliance. The bills will not include a safe harbor provision for using existing tax information. If the bills will be approved, they will take effect retroactively from January 1, 2024.
To access the draft of the Bill, click here.