Tax Administration Act, 2011 (Act No. 28 of 2011)NoticesReturn to be submitted by persons in terms of section 25 in terms of the Tax Administration Act, 2011 (Act No. 28 of 2011)2. Persons required to submit returns and form of returns |
| 2.1 | A Reporting Entity (other than a Surrogate Parent Entity) that is a resident must submit a return in the form and containing the information specified in the BRS: CbC and Financial Data Reporting relating to a CbC Report, a master file and a local file. |
| 2.2 | Where a filing obligation exists in terms of paragraph 2 of Article 2 of the Country-by-Country Regulations and the exceptions under paragraph 3 of Article 2 do not apply, a resident that is a Constituent Entity as identified in paragraph 2 of Article 2, must submit a return in the form and containing the information specified in the BRS: CbC and Financial Data Reporting relating to a CbC Report, a master file and a local file. |
| 2.3 | If the aggregate of a person’s potentially affected transactions for the year of assessment, without offsetting any potentially affected transactions against one another, exceeds or is reasonably expected to exceed R100 million, and that person is a resident, the person must submit a return in the form and containing the information specified in the BRS: CbC and Financial Data Reporting relating to a— |
| 2.3.1 | master file, where the ultimate holding company in respect of the Group that the person is a member of is a resident, or where a master file that substantially conforms with Annex I to Chapter V of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 is prepared by any other entity within the Group that the person is a member of; and |
| 2.3.2 | local file. |