GMT, CRS, and a Year-Long Fight Over Offshore Transfers: South Africa's International Tax Front, Explained

South Africa's Global Minimum Tax regime gives effect to the OECD/G20's GloBE Rules, adopted by more than 135 Inclusive Framework countries in October 2021, which require large multinational groups to pay an effective minimum tax of 15% on income in every jurisdiction where they operate. The rules apply to constituent entities within MNE groups that recorded consolidated annual revenue of at least €750 million in at least two of the four fiscal years preceding the tested year.

South Africa's own implementation has already slipped once: the GloBE registration and notification functionality on SARS eFiling, originally planned for December 2025, was pushed back to 16 March 2026, which SARS attributed to the need for its technology systems to align with evolving international standards. That delay cascaded into related deadlines, notification due dates moved to 30 April 2026, and GloBE Information Return (GIR) submission deadlines to 30 June 2026, for MNE groups whose fiscal years ended before 31 December 2024. Under the GMTAA itself, the standing rule is that a GIR is due 18 months after the end of an MNE group's first reporting fiscal year, and 15 months after year-end for every year thereafter.

On 21 September 2026, SARS announced the next phase, and it's a substantial expansion rather than a minor update. Administration now extends to: international information exchange, with SARS able to both receive GMT information submitted in foreign jurisdictions and exchange South African-sourced information with participating tax administrations, a capability underpinned by South Africa's earlier signing of the GloBE Information Return Multilateral Competent Authority Agreement (MCAA); a new GMT03 declaration process, specifically for cases where a foreign filing entity has submitted GMT information on behalf of a South African constituent entity, but SARS still needs to administer the local payment or correspondence obligation that arises from it; full payment administration, including payment reference number (PRN) management and payment clarification processes; assessments, covering both revised and estimated assessments, assessment notices, and validation-outcome correspondence; administrative penalties; and refund administration, for cases where GMT credits arise, subject to the usual validation, verification, and authorisation steps.

The GMT03 mechanism deserves particular attention from any South African entity that is part of a larger multinational group. It exists specifically because GMT compliance for a South African constituent entity can be satisfied through a filing made entirely outside South Africa, by a different group entity in another jurisdiction — but South Africa's own payment and correspondence obligations don't automatically disappear just because the underlying return was filed abroad. SARS's own guidance is direct on this point: affected groups should determine whether their obligations are being met through local filing, foreign filing, or some combination of the two, and specifically whether a GMT03 declaration is needed to support South Africa's administration and payment side of that arrangement. Groups relying entirely on a foreign filing entity should not assume that filing alone closes out every South African obligation.

Separately, South Africa has achieved qualified status for its own Domestic Minimum Top-Up Tax (QDMTT) rules under the OECD's peer review process — a designation that reduces the risk of another jurisdiction imposing a top-up tax on profits already taxed at the minimum rate in South Africa, since a qualifying domestic top-up tax is generally respected by other Inclusive Framework members rather than duplicated.

The Common Reporting Standard is the OECD framework underpinning automatic exchange of financial account information between tax authorities globally, and it has just undergone its most significant technical and policy overhaul since its original 2014 design. The industry shorthand distinguishes two related but separate updates: "CRS 2.0" refers to the policy and due-diligence amendments themselves, while "CRS Schema v3.0", the specific technical standard SARS's own materials reference, is the updated XML reporting format financial institutions must use to actually transmit the data, released by the OECD alongside a new User Guide (v4.0) in October 2024. Both need to advance together, and jurisdictions worldwide are rolling out the two in tandem.

South Africa is implementing from 1 March 2026, aligning with the timeline most major CRS jurisdictions have adopted. The most consequential substantive change is the expansion of what counts as a reportable financial account. The updated standard introduces Specified Electronic Money Products (SEMPs) — broadly, an electronic money product representing a digital version of a single fiat currency, issued on receipt of funds for payment purposes — which brings much of the wallet-based and account-like e-money sector into CRS scope for the first time, treating these products the same way a traditional Depository Account has always been treated. Central bank digital currency accounts are also expressly brought into scope. The practical effect is that many electronic money institutions and payment platforms are becoming CRS Reporting Financial Institutions for the first time, often without having previously carried any automatic-exchange reporting obligation at all.

The due-diligence and verification requirements have tightened alongside the expanded scope: enhanced controlling-person verification, more rigorous risk-based account reviews, and a change to how dual tax residency is handled — from 2026 onward, all of an account holder's residencies must be disclosed, rather than relying on a tie-breaker test to settle on a single reportable jurisdiction. One piece of transitional relief is worth flagging for institutions managing legacy accounts: where an account was already open before 31 December 2025 and controlling-person-role data isn't electronically available, reporting on that specific data point can be deferred until 2028, easing the immediate remediation burden on existing account books.

Institutions should begin collecting CRS-3.0-compliant data from 1 March 2026, with first XML submissions due by 31 May 2027 — and worth noting directly, this is the same collection-start and first-return timeline South Africa has set for the separate Crypto-Asset Reporting Framework (CARF), reflecting a coordinated OECD push rolling out multiple automatic-exchange upgrades on the same schedule. The first actual international exchange of 2026-year CRS data between tax authorities is scheduled for 2027, again mirroring CARF's own exchange timeline.

This is the item most likely to be misread as a small technical tweak. It isn't, it's the latest step in a genuinely contentious, year-long regulatory sequence, and understanding that sequence is necessary to understand what the 28 August 2026 relief actually does and, just as importantly, what it doesn't.

It started on 22 October 2025, when the South African Reserve Bank's Financial Surveillance Department issued Exchange Control Circular 15/2025, fundamentally changing how non-residents could transfer South African-sourced income abroad. Before this circular, non-residents needed SARS's Approval for International Transfer (AIT) tax compliance status only when transferring capital out of the country — ordinary income could simply be remitted without that additional approval. The October 2025 changes brought several categories of income into the AIT requirement for the first time: dividends, profits and income distributions, directors' fees, trust income, and rental income. Other income types — interest, salaries, fees for services rendered, pensions, and annuities — remained exempt.

The backlash was immediate and substantial. The Institute for International Tax and Finance and other market participants warned that the changes imposed a disproportionate administrative burden, particularly given that even relatively small, routine income amounts now triggered the full AIT process — which requires proof of non-residency status, a detailed source-of-funds declaration, recent bank statements, and a statement of assets and liabilities covering the preceding three years. Non-residents not even registered with SARS faced an equivalent manual "Letter of Compliance" requirement before any funds could move. Critics specifically noted this landed at a sensitive moment for foreign investor sentiment, following a sustained multi-year decline in offshore ownership of South African equities.

SARB partially retreated roughly two months later. Revised guidance from the Financial Surveillance Department removed the AIT requirement for non-resident entities transferring amounts within the R1 million Single Discretionary Allowance; for amounts above that threshold, the existing R10 million foreign capital allowance framework applies instead, still requiring SARS tax clearance and SARB approval. The Institute for International Tax and Finance welcomed this as a partial but incomplete reversal, and continued pushing for further reform — parity between resident and non-resident treatment, removing the distinction between different income types, and a faster, more proportionate AIT process generally.

Enforcement then tightened again on the ground. By 13 March 2026, the Exchange Control Manual had been updated to formally replace the older "good standing" Tax Clearance Certificate approach with a mandatory AIT certificate requirement for these transfers — a change that reportedly triggered banks freezing the accounts of individuals attempting transfers without the correct clearance in place, in some cases very quickly after the attempted transaction.

Against that backdrop, the 28 August 2026 update is a genuinely welcome, if narrow, administrative fix. SARS updated its Guide to the Tax Compliance Status functionality on eFiling to confirm that non-resident directors, and non-residents earning rental income, who make multiple transfers of that income during a year no longer need to submit a separate AIT application for each individual transfer. A single annual application, based on the estimated annual value of the relevant directors' fees or rental income, now suffices — addressing, for example, the specific pain point of a non-resident landlord who had previously faced a fresh AIT application every single month simply to remit routine rental income already accounted for.

The relief is narrower than "non-residents get AIT relief" headlines might suggest, and this distinction matters. SARS's own update applies specifically to directors' fees and rental income — the two categories most likely to involve genuinely recurring, predictable transfers. Dividends, trust distributions, and other income categories the October 2025 circular also brought into AIT scope are not covered by this relief and, based on available sourcing, still require a separate AIT application per transfer. The relief is also on the number of applications required, not on the underlying evidentiary burden — the same supporting documentation (rental agreements, proof of reasonable rental value, source-of-funds evidence, and so on) is still required to obtain the single annual approval.

Who must act, and what specifically changes — GMT: In-scope MNE groups should confirm, without delay, exactly how their South African constituent entity's obligations are being met — locally, through a foreign filing entity, or a combination — and specifically whether a GMT03 declaration is needed to cover SARS's local payment and correspondence requirements where a foreign entity has filed on the group's behalf.

Who must act — CRS Schema 3.0: South African financial institutions, and especially e-money providers, payment institutions, and digital wallet platforms that have never previously carried CRS reporting obligations, need onboarding, due-diligence, and data-capture processes compliant with the new standard in place well ahead of the 31 May 2027 first-return deadline, given the scale of the classification and systems work involved.

Who must act — AIT: Non-resident directors and landlords making regular, recurring South African-sourced income transfers should apply for the single annual AIT covering their estimated annual income, rather than continuing to file per-transfer applications. Anyone receiving dividends, trust distributions, or other income types not covered by this specific relief should not assume the same simplification applies to them.

Financial and operational exposure: For GMT, the newly live administrative penalty capability means non-compliance around payment, correspondence, or declaration obligations now carries real, currently-enforceable consequences, not merely a registration formality. For CRS, misclassifying a digital wallet or e-money product as out of scope under the old framework is now a live compliance gap, not a theoretical one. For AIT, the underlying documentation burden persists even where the number of applications has been reduced — this is an efficiency gain, not a reduction in disclosure requirements.

Realistic timeline: GMT's expanded administration is live now. CRS Schema 3.0 data collection began 1 March 2026, with first submissions due 31 May 2027. The AIT relief has applied to new applications since 28 August 2026.

What remains uncertain or pending: Whether SARS or SARB will extend the single-annual-application relief to dividends and trust distributions, the other income categories the October 2025 circular also brought into AIT scope, has not been announced. The Institute for International Tax and Finance's broader reform requests — full parity between resident and non-resident treatment, and elimination of income-type distinctions altogether — remain unaddressed as of this writing.

Does the Global Minimum Tax apply to my business? Only if your group's consolidated annual revenue reached at least €750 million in at least two of the four fiscal years before the tested year. This is a large-multinational-group regime, not a general corporate tax change.

If our GMT return is filed by a group entity in another country, does South Africa have nothing further to do? Not necessarily. SARS may still require a GMT03 declaration and may still administer local payment or correspondence obligations even where the underlying GloBE Information Return was filed entirely outside South Africa. Confirm this directly rather than assuming a foreign filing closes out every local requirement.

Does CRS Schema 3.0 affect my crypto wallet or e-money app provider? Potentially, yes. The updated standard brings Specified Electronic Money Products — broadly, digital wallet-style products representing a single fiat currency — and central bank digital currency accounts into CRS scope for the first time, meaning some providers are becoming reporting financial institutions for the first time.

Do I need a new AIT application every time I receive rental income from my South African property? No, not anymore, provided you are a non-resident landlord. Since 28 August 2026, you can submit a single annual AIT application based on your estimated annual rental income rather than one application per transfer.

Does this AIT relief also cover dividends I receive from a South African company? No. The relief specifically covers directors' fees and rental income. Dividends and trust distributions, though also brought into AIT scope by the October 2025 exchange control changes, are not covered by this specific update based on available sourcing.

Why did non-residents suddenly need AIT approval for income transfers in the first place? The South African Reserve Bank's Exchange Control Circular 15/2025, issued 22 October 2025, extended the AIT requirement — previously limited to capital transfers — to cover several categories of income, including dividends, directors' fees, trust income, and rental income, following concerns about verifying the tax position behind these outflows.