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Corporate Tax & Multinational Advisory

Submit Large Business & International (LBI) Query

Escalate complex corporate income tax (ITR14), Section 31 transfer pricing, Controlled Foreign Company (CFC), and international tax queries directly to the specialized SARS LBI division.

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eFiling Navigation & Turnaround

LBI Portal Path & Specialist SLA

Acknowledgement: 48 Hours | Technical Resolution: 10–21 Business Days

eFiling Navigation Path: Log into eFiling → Returns → Income Tax (ITR14) / Transfer Pricing (CbCR, Master & Local File)

Verified SARS Portal

Submit a SARS LBI Query Online

Access official SARS digital channels to lodge technical corporate and international tax inquiries.

LBI Query Instructions

How to Submit an LBI Query to SARS

01

Access the SARS LBI Online Query Portal on SOQS

Navigate to tools.sars.gov.za/sarsonlinequery/LBCQuery or log into your corporate SARS eFiling portfolio.
02

Confirm LBI Taxpayer Segmentation Criteria

Verify that your group meets SARS LBI segmentation rules: gross turnover exceeding R300 million per annum, net asset value > R100 million, JSE-listed entity, financial institution, or multinational enterprise (MNE) group.
03

Select Technical Tax Stream & Assigned Relationship Manager

Select your specialist stream: Corporate Income Tax (ITR14), Section 31 Transfer Pricing / CbCR, Section 9D Controlled Foreign Companies (CFC), Section 23M/23N Interest Limitation, or DTA Withholding Relief.
04

Attach Technical Position Paper & Supporting Schedules

Upload your signed Power of Attorney, group organogram, Master File / Local File transfer pricing documentation, or Section 42/45/47 corporate reorganisation schedules.
05

Track LBI Case Reference & Specialist Escalation

SARS LBI logs a dedicated case number and routes the submission to your assigned LBI Relationship Manager (initial acknowledgement within 48 hours; technical review 10–21 business days).
Corporate Compliance Risks

Common LBI Segmentation & International Filing Pitfalls

Non-LBI Entities Routed Back to Standard Contact Centre

If an SME that does not meet the LBI turnover, asset, or multinational group thresholds submits a query on the LBCQuery portal, SARS rejects the ticket and redirects it to the standard SMME queue.

Late Master File / Local File Transfer Pricing Uploads

Cross-border connected-party transactions exceeding R100 million require mandatory Transfer Pricing Master File and Local File uploads on eFiling within 12 months of financial year-end.

Using LBI Queries for Formal Advance Tax Rulings (ATR)

Binding Private Rulings (BPR) and Binding Class Rulings (BCR) under Chapter 7 of the Tax Administration Act cannot be issued via SOQS LBCQuery—they must be lodged on the dedicated SARS eFiling ATR module.

Missing IT10B Controlled Foreign Company (CFC) Schedules

Corporate ITR14 returns for South African holding companies with >50% foreign subsidiary participation rights are flagged for LBI audit if Form IT10B and foreignAFS are omitted.

Frequently Asked Questions

What is the SARS Large Business & International (LBI) division?

SARS Large Business & International (LBI) is the specialist enforcement and relationship centre servicing JSE-listed groups, multinational enterprises, state-owned entities, financial institutions, and large corporate groups.

What is the turnaround time for a SARS LBI query on SOQS?

SARS LBI acknowledges receipt with a case reference number within 2 business days and typically assigns a Relationship Manager or technical specialist to respond within 10 to 21 business days depending on issue complexity.

When must Transfer Pricing Master and Local Files be submitted on SARS eFiling?

Where aggregate cross-border potentially affected transactions with connected persons exceed (or are reasonably expected to exceed) R100 million in a year of assessment, the Master File and Local File must be uploaded via eFiling ("Returns > Transfer Pricing") within 12 months of the financial year-end.

Can LBI queries be used to resolve Section 42–47 corporate restructuring disclosures?

Yes. Reportable arrangement notifications and corporate rollover relief disclosures under Sections 42, 44, 45, and 47 of the Income Tax Act can be coordinated directly with your LBI Relationship Manager.

Does My Accountant provide corporate tax and Fractional CFO support for mid-market and group entities?

Yes! Our Chartered Accountants and registered tax practitioners advise corporate groups on multi-entity consolidations, Section 42/45 restructurings, international withholding taxes, and SARS LBI audit responses.

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