Zasha de Lange | Manager | Trust and Deceased Estate | Tax Compliance | Tax Consulting SA | mail me |
In its drive to meet the ambitious 2025/26 revenue estimate of R1.986 trillion, the South African Revenue Service (SARS) has made its expectations clear. Timely, transparent and accurate tax submissions are now the new normal.
Central to this approach is the expanded use of third-party data. This applies broadly, including trusts and Non-Profit Organisations (NPOs).
Following the Budget Speech on 21 May 2025, SARS reaffirmed its commitment to strengthening revenue collection. This is critical to supporting the delivery of public services. To close the tax gap, SARS compliance continues to be a focus. It is also leveraging cutting-edge technologies. These include advanced data analytics and artificial intelligence.
SARS closely inspects submissions such as the IT3(d) and IT3(t) forms. By doing so, it raises automated tax assessments for individuals. This allows quicker detection of underreported income and expands SARS’s reach into unregistered or non-compliant taxpayer populations. A special focus has been placed on trusts and NPOs.
NPOs on the radar – IT3(d) submissions and S18A compliance
Section 18A-approved NPOs must submit IT3(d) forms to SARS. These forms report all tax-deductible receipts issued to donors during the year of assessment.
SARS uses this data to cross-reference donor claims. This ensures that tax deductions are valid and properly disclosed. It also supports the integrity of the public benefit sector by promoting transparency and maintaining donor trust.
Failure to submit accurate IT3(d) forms presents serious risks:
- Loss of Section 18A approval, making future donations non-deductible.
- Potential SARS audits and penalties for non-compliance.
- Loss of donor confidence, which may impact future fundraising efforts.
SARS expects accuracy from the outset. Incomplete or incorrect data causes delays. It also undermines the organisation’s credibility with donors and regulators.
Trusts under scrutiny – IT3(t) and Beneficial Ownership transparency
Trusts are now firmly under the compliance spotlight. The IT3(t) form, which is an annual reporting requirement, ensures that income and capital gains distributed to beneficiaries are properly disclosed and taxed.
Beyond financial reporting, SARS compliance means reinforced expectations around beneficial ownership transparency. Trustees must ensure that SARS receives correct and complete information about the individuals who benefit from trust income or assets.
The deadline for IT3(t) submissions is 30 September 2025.
Trustees should note the following:
- SARS is using third-party data to identify and register previously unregistered trusts.
- Trustees are personally and jointly liable for a trust’s tax compliance.
- SARS is expected to impose administrative penalties for non-compliance. This includes failing to submit IT3(t) or income tax returns.
- Passive or inactive trusts are not exempt. All trusts must meet annual tax return obligations.
SARS’s 2025 guidance confirms that no trust is legally considered “dormant”. Fiduciary obligations remain, even in the absence of active trading or distributions.
SARS sharpens focus on trusts through data-driven compliance
SARS compliance strategy relies heavily on technology. By combining data from IT3(d) and IT3(t) submissions with other sources like banking and payroll records, SARS can automate assessments and detect discrepancies early.
This forms part of a broader compliance initiative known as Project AmaBillions. The programme operates on the assumption that most taxpayers want to comply. However, SARS is prepared to enforce the law when needed.
To achieve this, SARS will use legal instruments and sophisticated data systems. These tools will help identify, audit and hold accountable those who fail to meet their tax obligations.
Act now! The clock is ticking
The first quarter of 2025 has already passed. Submission deadlines for both IT3(d) and IT3(t) are now fast approaching.
Whether you are a trustee or manage a public benefit organisation, early and accurate compliance is critical. Professional assistance from accountants, lawyers or tax consultants is no longer a luxury. It has become a necessity.
Engaging qualified professionals streamlines the submission process. It also helps to establish lasting frameworks for governance and compliance.
With SARS adopting automated systems and intensifying enforcement efforts, the time to align your reporting practices is now. Doing so is the most prudent and responsible step forward.
