What Every Trustee Must Do 🏛️
If you’re a trustee, this one’s for you, and it’s time-sensitive 🏛️
Trust Filing Season 2026 opened on 19 September 2026 and runs until 22 January 2027, and SARS has made it clear this is not a season to take lightly. The revenue service is turning up the heat on trusts, with a particular focus on nil returns, assessed losses, and the accurate disclosure of trust assets and income. Here’s what every trustee needs to do.
🏛️ Every trust must file, yes, even dormant ones
Here’s the point that catches so many trustees out: a trust is a “person” under the Income Tax Act, which means every trust is a taxpayer, and must file a return every year. That includes trusts that are dormant, inactive, or economically doing nothing at all.
If you’re a trustee of a family trust that’s been sitting quietly for years, “we don’t do anything with it” is not a reason to skip filing. It’s exactly the kind of trust SARS is now scrutinising 🚩
The return you file is the ITR12T (the Income Tax Return for Trusts), submitted via eFiling.
📋 What you need to file
SARS requires the return plus mandatory supporting documents. Have these ready:
📄 The trust instrument (trust deed or will)
📊 Annual financial statements or administration accounts
✅ Letters of Authority from the Master of the High Court
📝 Resolutions and minutes of trustee meetings
🧑🤝🧑 A beneficial ownership declaration / organogram showing who ultimately benefits
💰 Income and expenditure records, and proof of any tax credits
Missing documents are one of the most common reasons trust filings stall, gather them before you start.
🔍 The beneficial ownership focus
A major theme in recent years, and enhanced again for 2026, is beneficial ownership. The ITR12T now has an improved beneficial-ownership declaration page requiring you to record all beneficial owners and anyone who may ultimately benefit from the trust or its assets. This flows from South Africa’s anti-money-laundering reforms, and it’s mandatory: without the beneficial ownership declaration, the return cannot be filed.
SARS has also made tax practitioner contact details a required field, and improved the founder questions, so accuracy on who’s who in the trust matters more than ever 📋
❓ Is my trust even registered with SARS?
This trips up more trustees than you’d think. Registering a trust with the Master of the High Court is not the same as registering it with SARS. A trust must be registered for income tax within 21 days of registering with the Master, and many older trusts simply never were. If yours isn’t registered for tax, that needs sorting before you can file. When in doubt, check.
❓ What if my trust has ceased operating?
Deregistering with the Master does not automatically deregister the trust with SARS. If a trust has genuinely wound up, you must take separate steps to deregister it with SARS, after ensuring its tax affairs are fully up to date. Until you do, the annual filing obligation continues, dormant or not 🔍
❓ Do beneficiaries need to do anything?
Yes. Beneficiaries who received income from a trust must declare that income in their own personal tax returns. Trust income doesn’t just disappear at the trust level, it flows through, and SARS now pre-populates a lot of this from the trust’s third-party (IT3(t)) data, so mismatches are easily spotted.
🎯 Don’t let your trust become a target
SARS has been explicit that trusts are a compliance focus area, and the days of a dormant family trust quietly escaping attention are over. Filing correctly, on time, with complete documents and accurate beneficial-ownership disclosure is simply non-negotiable now.
Go2 Accounting helps trustees across Pretoria and Tshwane (and clients across South Africa) meet their trust obligations, ITR12T returns, financial statements, beneficial ownership and the supporting documents SARS demands, accurately and on time. Get in touch well before the 22 January 2027 deadline.
Because being a trustee is a legal responsibility, and SARS is watching how you handle it 😉
