While most of the proposals are set to take effect from 1 July 2025, two specific measures are scheduled for implementation from 1 January 2026. These include the introduction of Advance Pricing Agreements (APAs) for transfer pricing purposes and a provision for the waiver of penalties and interest arising from errors caused by electronic tax systems. These timelines are contingent on the Bill being passed and assented to by the President no later than 30 June 2025.

The release of the Finance Bill, 2025 comes shortly after the withdrawal of the Finance Bill, 2024, and follows tax and legal reforms that were introduced through the Tax Laws (Amendment) Act, 2024, the Tax Procedures (Amendment) Act, 2024, and the Business Laws (Amendment) Act, 2024, all of which took effect from 27 December 2024.

Among the key highlights of the 2025 Bill are the clarification of the due date for the Minimum Top-Up Tax, which applies to multinational enterprises based on a defined Combined Effective Rate of Tax; the proposal to introduce a five-year cap on carrying forward tax losses; and significant enhancements to the taxation of the digital economy across Income Tax, VAT and Excise Duty regimes.