According to recent reports, the South African National Assembly approved the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 31 August 2022. After the internal ratification process is completed, South Africa must deposit its ratification instrument to bring the MLI into force for its covered agreements (tax treaties).
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, and 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 provisional list of reservations and notifications at the time of signature. A definitive list will be provided when the ratification instrument is deposited.