Tax – Transfer pricing

Updated lists of countries made available for purposes of Country-by-Country Reporting

The list of countries that have a current International Agreement in place with South Africa, but do not have a Qualifying Competent Authority Agreement in place for purposes of Article 2(2) of the regulations specifying the Country-by-Country Reporting Standard, has been updated.
Updated lists of countries having an International Agreement in place with South Africa for purposes of Article 2(2) have been made available. The lists are intended to assist members of Multi-National Entity (“MNE”) Groups tax resident in South Africa in complying with their obligations under Article 2(2)(ii)(b) of the Country-by-Country reporting Regulations.

The Ultimate Parent Entity or other Multi-National Entity ("MNE") must submit the required information as stipulated in the Business Requirements Specification ("BRS"): Country-by-Country and Financial Data Reporting document, as previously issued by SARS. Local filing of a Country-by-Country ("CbC") Report (referred to as the CbC01) by others members of an MNE Group is required in the circumstances as described in Article 2(2) read with Article 2(3) of the CbC Regulations. 

The recently updated list of countries that have a current International Agreement in place with South Africa but do not have a Qualifying Competent Authority

Agreement in place is available here. 
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