Global Minimum Tax Act, 2024

The text provided is not a court judgment but a South African statute published in the Government Gazette. It records that the President assented on 20 December 2024 to the Global Minimum Tax Act, 2024, published on 24 December 2024. The Act introduces the OECD/G20 Inclusive Framework Global Anti-Base Erosion (GloBE) Rules into South African law, imposes a Top-up Tax and a Domestic Minimum Top-up Tax on qualifying multinational enterprise groups, defines relevant terms, incorporates the GloBE Model Rules subject to specified modifications, provides for liability of domestic constituent entities and domestic joint ventures, empowers the Minister to recognise later OECD/Inclusive Framework guidance by notice, and states that the Act is deemed to have come into operation on 1 January 2024 for fiscal years beginning on or after that date.

• No judicial legal issues can be extracted because the text is legislation, not a decided case.
• The statute itself addresses the implementation in South Africa of the OECD/G20 GloBE global minimum tax framework.
• It regulates when and how Top-up Tax and Domestic Minimum Top-up Tax apply to domestic constituent entities, domestic joint ventures, and related entities within in-scope multinational enterprise groups.

The Global Minimum Tax Act, 2024 was assented to by the President on 20 December 2024, published in Government Gazette No. 51830 on 24 December 2024, and deemed to have come into operation on 1 January 2024, applying to fiscal years beginning on or after that date.

Not applicable. There is no ratio decidendi because this is not a judicial decision. The closest equivalent legislative principle is that South Africa adopts the GloBE Model Rules, subject to the Act's specified modifications, and imposes Top-up Tax and Domestic Minimum Top-up Tax on qualifying domestic entities and joint ventures within in-scope multinational enterprise groups.

Not applicable. There are no obiter dicta because the text is a statute and contains no judicial observations.

Although not a court case, the Act is significant because it introduces South Africa's domestic implementation of the OECD/G20 Pillar Two global minimum tax framework. It aligns South African tax law with international anti-base erosion standards, creates a Top-up Tax and Domestic Minimum Top-up Tax for in-scope multinational enterprise groups, and provides a mechanism for incorporating future Inclusive Framework guidance. It is important in South African fiscal jurisprudence and tax administration because it reflects the Republic's adoption of coordinated global minimum tax norms and will affect the taxation of large multinational groups operating in or through South Africa.