Global Minimum Tax Act, 2024 (Act No. 46 of 2024)

Part IV : Domestic Minimum Top-up Tax

E. Transition Rules

17. Transition Year
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Except where section 18 applies, the Transition Year for the Republic shall be the earlier of the Fiscal Year in which the MNE Group first becomes subject to this Act or the first Fiscal Year that Domestic Constituent Entities, Domestic Joint Ventures and Domestic Joint Venture Subsidiaries of the MNE Group become subject to a Qualified IIR or Qualified UTPR in another jurisdiction.