South Africa

Corporate - Other issues

Last reviewed - 10 December 2020

Intergovernmental agreements (IGAs)

South Africa entered into an agreement with the United States to improve international tax compliance and to implement the Foreign Account Tax Compliance Act (FATCA). The date of entry into force is 28 October 2014.

South Africa is also a party to the Multilateral Convention on Mutual Administrative Assistance on Tax Matters as well as a number of bilateral tax information exchange agreements. As a signatory to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information, also referred to as the Common Reporting Standard (CRS), South Africa enacted domestic enabling legislation. The first exchange date was September 2017. South Africa also has bilateral CRS agreements with Hong Kong and Singapore.

Base Erosion and Profit shifting (BEPS)

South Africa is a member of the OECD’s Inclusive Framework on BEPS and has been amongst the first adopters of BEPS Actions in general. Notably, South Africa:

  • was amongst the first batch of signatories to the so-called Multilateral Instrument (MLI) in June 2017, and
  • enacted (in 2016 and 2017) domestic regulations to enact transfer pricing documentation requirements aligned with Chapter V of the OECD’s 2017 Transfer Pricing Guidelines (also referred to as BEPS Action 13), including the exchange of Country-by-Country Reports.