On 30 September 2022, South Africa deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Based on the date of deposit, the MLI will enter into force for South Africa on 1 January 2023, although its entry into force for South Africa's covered agreements (tax treaties) will depend on the ratification of the MLI by the counterparty to a particular covered agreement.
The MLI will generally enter into force for a particular covered agreement on the first day of the month following a three-month period after both parties to the covered agreement have deposited their ratification instrument. Once in force, the provisions of the MLI will generally apply for a covered agreement from 1 January of the year following its entry into force in respect of withholding taxes, although those that come into force on 1 January 2023 will generally apply from 1 January 2023. The MLI will generally apply for all other taxes with respect to taxable periods beginning on or after the expiration of a 6-month period following the date of entry into force.
Click the following link for South Africa's definitive list of reservations and notifications made upon deposit of the ratification instrument (document forthcoming at time of writing).