SARS Trust Filing Season 2026: What Family Businesses Need to Get in Order

SARS opened trust filing season on 19 September 2026, with the window for the Trust Income Tax Return (ITR12T) closing on 22 January 2027. For many family businesses across Limpopo, the trust behind the operating company has always been the quiet part of the structure – set up once, reviewed rarely, filed without much scrutiny. This year that habit carries more risk than usual, because SARS has built a full beneficial ownership declaration directly into the ITR12T. Getting the trust’s affairs in order is no longer a once-a-year formality; it is a matter of proper business order, applied to a part of the structure that has gone without it for too long.

Key Facts at a Glance

Trust filing season 2026 opens 19 September 2026 and closes 22 January 2027 for the ITR12T (Trust Income Tax Return).

Applies to all registered resident trusts and qualifying non-resident trusts required to submit under SARS’s annual public notice.

IT3(t) third-party data returns, covering distributions made to beneficiaries, are due by 30 September 2026.

The ITR12T now includes a dedicated beneficial ownership declaration page, with enhanced questions for founders who are deregistered legal entities or who have passed away.

Trusts must register with SARS within 21 days of registration with the Master of the High Court.

Any change to a trust’s registered details must reach SARS within 21 business days.

Provisional tax dates for trusts: 31 August 2026 (first payment, 2027 year of assessment), 30 September 2026 (top-up payment, 2026 year of assessment), and 28 February 2027 (second payment, 2027 year of assessment).

Tax practitioner contact details are now a mandatory field on the ITR12T.

Trustees carry personal liability for the trust’s tax compliance.

A Trust Deserves the Same Order as the Business It Supports

Family businesses in and around Modimolle are frequently structured with a trust holding shares in the operating company, or holding farmland, property, or the assets built up for the next generation. The operating company usually gets proper attention – accounts prepared monthly, VAT and payroll reconciled on schedule. The trust above it often does not receive the same discipline, treated instead as a document filed away once the structure was set up and rarely revisited.

That approach was workable while SARS treated the trust return as low-risk administration. It no longer is. A trust with an outdated asset register, an unreported change of trustee, or beneficiary details that were never updated is not simply behind on paperwork – it is a structure that cannot currently demonstrate the order SARS now expects of it. Bringing a trust’s records up to standard is exactly the kind of work that belongs alongside sound accounting and advisory practice, not separate from it.

What Has Changed: Beneficial Ownership Now Sits Inside the ITR12T

Until this filing season, beneficial ownership information for trusts sat mainly with the Master of the High Court, separate from the annual tax filing. SARS has now pulled that requirement directly into the ITR12T. Trustees must identify and declare every beneficial owner of the trust – every natural person who ultimately owns, controls, or may benefit from the trust or its assets, whether directly or through another entity.

In practice, this means listing the founder, every trustee, and every beneficiary, including beneficiaries who form part of a defined class rather than being named individually, plus anyone who exercises effective control over the trust without holding a formal position. SARS has also added handling for two situations that regularly complicate older family trusts: a founder that was a legal entity later deregistered, and a founder who has since passed away. Both now have a proper pathway on the return rather than an awkward gap.

This mirrors the beneficial ownership transparency companies have faced through CIPC for some time. SARS is closing the same gap for trusts, and family businesses running both a trading company and a holding trust should expect the two to be looked at together, not in isolation.

Before 22 January 2027: What to Put in Order

Trustees carry personal liability here, so this is worth working through properly rather than leaving until the deadline is close:

Confirm SARS registration is current. Registration is required within 21 days of registering with the Master of the High Court – worth checking for trusts established some years ago.

Report any outstanding changes. Trustee appointments, resignations, or amendments to the trust deed must reach SARS within 21 business days of the change.

Compile a complete asset and income schedule. Full disclosure is required, including passive assets such as farmland, a holiday property, or a shareholding that produced no income this year.

Gather the full beneficial ownership picture. Founder, trustees and beneficiaries, with particular attention to any deceased or deregistered founder.

Diarise the provisional tax dates. 31 August 2026, 30 September 2026 (top-up), and 28 February 2027 each carry their own obligations.

Have your tax practitioner’s details ready. This is now a mandatory field on the ITR12T.

Remember the IT3(t) deadline. Distributions to beneficiaries must be reported separately by 30 September 2026, ahead of the main filing.

Order in Business, Applied to Your Trust

This is the kind of structure and discipline we bring to every part of a client’s business, not only the operating company. Our team works through the ITR12T and its new beneficial ownership requirements as part of the broader taxation and advisory support we provide to family businesses across Modimolle and the wider Limpopo region, so trustee records, beneficiary details and provisional tax obligations are kept current throughout the year rather than assembled in a rush before January.

A trust that has not had a proper review in some time is not unusual – many were established years ago and simply carried on. What matters now is bringing it back into order before the deadline arrives, with a team that understands both the trust and the business it supports.

Frequently Asked Questions

Q: Does a trust have to submit an ITR12T even if it earned no income? A: Yes. Registered trusts required to submit under SARS’s annual public notice must file an ITR12T regardless of whether the trust generated income, since the return also requires disclosure of assets and expenditure, including passive, non-income-producing assets.

Q: Who counts as a beneficial owner of a trust under the new ITR12T rules? A: A beneficial owner is any natural person who ultimately owns, controls, or may benefit from the trust or its assets – typically the founder, every trustee, and each beneficiary, along with anyone who exercises effective control over the trust without a formal appointment.

Q: What happens if a trustee misses the 22 January 2027 deadline? A: A late or incomplete ITR12T exposes the trust to SARS penalties and interest, and because trustees are personally liable for the trust’s tax compliance, those consequences can extend to the individual trustees rather than stopping at the trust itself.

Trust filing season 2026 closes on 22 January 2027, and with beneficial ownership now built into the return, this is not a year to leave the trust’s affairs until the last few weeks. If your family business’s trust could use a proper review – registration, beneficial ownership records, or the provisional tax calendar – get in touch with WV Rekenmeesters and let’s bring it into order well before the deadline.