Look at the following Guide on CBC by SARS at page 23:
SARS 2018 cbc – How to complete and submit your Country by Country information – External Guide
Here SARS suggests you include dividends. This should not be read as increasing the R100m MNE threshold for “affected transactions” unless those dividends are linked to an “affected transaction”.
This is a guideline and not law.
Here is the SARS original explanation of CBC reporting on their website:
SARS 2018 CBC Country-by-Country(CbC)
Take a look at the definition of “affected transaction” in section 31 of the Income Tax Act, 1962, and check if the reported dividends should be included to push up the R100m threshold for CBC reporting purposes.