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How do I submit Country-by-Country reporting information to SARS?
How do I submit Country-by-Country reporting information to SARS?
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Direct answer
SARS's Country-by-Country external guide, revision 7 effective 28 May 2026, describes how to complete and submit the CBC01 form and submit a CbC report, master file and local file through eFiling. It also covers activation of the CbC functionality, user rights, XML upload, checking whether documents submitted successfully and correction requests.
Do not begin with the upload. First establish the reporting entity, tax period, required deliverables and authorised eFiling users. The guide explains the process, while the group must still determine its applicable reporting obligation under the current rules.
What this means in practice
The CbC process is a linked set of controls. The guide's contents include activation, user-rights management, access to the CbC financial report, CBC01 completion, OECD XML upload, declaration, submission of master and local files, correction and SARS communications. A team should assign ownership for each control instead of leaving the work to a single last-day uploader.
SARS explains that the guide describes the submission process for a CbC report and or master and local files via eFiling. It does not say every multinational must submit all three items in every circumstance. Determine the group role, South African entity role and relevant reporting period before selecting the package to submit.
Use revision-controlled source data. Retain the version of every document and data file used for the final submission. Where information changes after review, repeat the reconciliation so that CBC01, XML and supporting files do not describe different group structures or periods.
Step-by-step
- Establish the reporting perimeter. Identify the reporting entity, constituent entities, group period, relevant contacts and which CbC information is required. Get technical confirmation where the obligation is uncertain.
- Read the current SARS external guide and check its effective date. The current guide is revision 7, effective 28 May 2026. Do not build a filing process around an old internal checklist without comparing it to the current SARS instructions.
- Activate CbC functionality in the correct eFiling profile and confirm user rights. The guide has separate sections for activation, managing user rights and managing users in the group. Test access before the filing deadline.
- Prepare the CBC01 workpapers. Reconcile reporting-entity details, contact information, addresses, revenue, constituent entities, business activities and other information to the approved group data.
- Prepare the CbC XML file where required and validate it against the applicable OECD CbC XML Schema and SARS process. Preserve the technical validation output, file checksum or version identifier and source-data reconciliation.
- Request the CbC financial report in eFiling, complete CBC01 and upload the required XML or documents. Use a second reviewer to compare the final eFiling selections with the approved submission pack.
- Submit and check the result. The guide includes a section on determining whether documents submitted successfully. Save the acknowledgement and monitor the case rather than assuming an upload screen proves final submission.
- Use the guide's correction route if a material error is identified. Retain original and corrected records, the reason for correction and the SARS outcome.
Documents and records to keep
- Obligation analysis, group diagram and reporting-period calendar.
- CBC01 workpapers, approved CbC XML and master or local files.
- Access and user-rights evidence.
- Validation output, acknowledgements and SARS correspondence.
- Correction records, if any.
Important limits and exceptions
SARS's guide notes that South African CbC regulations define impacted MNEs by consolidated group revenue and describes situations involving a South African-resident ultimate parent or constituent entity. Thresholds and role tests are not a shortcut to a filing decision. Obtain advice for the applicable regulations and facts.
A successful technical submission does not validate the tax, transfer-pricing or legal accuracy of the information. Secure access is also not proof that the right entity has been selected. Keep professional review and submission administration separate.
When to get tailored advice
Get tailored advice where the group has a foreign ultimate parent, a surrogate filing entity, multiple South African entities, missing master-file information or a changed group structure. Escalate promptly if SARS rejects the XML, the team cannot determine the reporting entity or an original report requires correction.