1. Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?
  2.  What is the implementation status of Pillar Two/GloBE rules?
  3.  Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?
  4.  When will the Income Inclusion Rule (IIR) come into force?
  5.  When will the Undertaxed Payments Rule (UTPR) come into force? 
  6.  Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?
  7. Further comments

jurisdiction

South Africa
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1.Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?

Yes.

2. What is the implementation status of Pillar Two/GloBE rules?

Not yet initiated.

3. Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?

N/A.

4. When will the Income Inclusion Rule (IIR) come into force?

Unclear.

5. When will the Undertaxed Payments Rule (UTPR) come into force? 

Unclear.

6. Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?

Unclear.

7. Further comments

22 February 2023: South Africa announced in its 2023 Budget Review that the government planned to introduce Pillar Two rules. Legislative amendments are expected to be introduced in the 2024 bill.