In its effort to meet the ambitious 2025/26 revenue estimate of R1.986 trillion, the South African Revenue Service (Sars) has made it clear that timely, transparent and accurate tax submissions are the new normal. Central to this approach is expanded use of third-party data, not sparing Trusts and Non-Profit Organisations (NPOs).

Following the Budget Speech on 21 May 2025, Sars reaffirmed their commitment to strengthening revenue collection as it is vital in supporting the delivery of public services. 

Sars reiterated its focus on tax compliance and leveraging cutting-edge technologies to close the tax gap.

This includes closely inspecting submissions such as the IT3(d) and IT3(t) reports to Sars. By using advanced data analytics and artificial intelligence Sars is then able to raise automated tax assessments for individuals. This allows quicker detection of underreported income, and a broader reach into the unregistered or non-compliant taxpayer populations, with a focus on Trusts and Non-Profit Organisations (NPOs).

NPOs on the Radar: IT3(d) Submissions and S18A Compliance

Section 18A-approved NPOs are required to submit IT3(d) forms to Sars, reporting all tax-deductible receipts issued to donors during the year of assessment.

Sars uses this data to cross-reference donor claims and ensure that tax deductions are valid and correctly disclosed. The process also preserves the integrity of the public benefit sector by maintaining transparency and enabling donor trust.

Failure to submit accurate IT3(d) forms by the 31 May 2025 deadline poses serious risks, including:

• Loss of Section 18A approval, making future donations non-deductible;
• Potential Sars audits and penalties for non-compliance;
• Loss of donor confidence, which may affect future fundraising efforts.

Sars expects accurate submissions from the outset. Incomplete or incorrect data not only causes delays but may undermine the organisation’s standing with donors and regulators alike.

Trusts Under Scrutiny: IT3(t) and Beneficial Ownership Transparency

Trusts are equally under the compliance spotlight. The IT3(t) form, now an annual reporting requirement, ensures that income and capital gains distributed to beneficiaries are disclosed accurately and taxed appropriately.

In addition to financial disclosures, Sars has reinforced its expectations around beneficial ownership transparency. Trustees must ensure that Sars is accurately informed of the individuals who ultimately benefit from trust income or assets.

The deadline for IT3(t) submissions is 30 September 2025.

Trustees should take note:

• 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.
• Administrative penalties are expected to be imposed on non-compliant trusts, particularly for the non-submission of IT3(t) or income tax returns.
• Passive or inactive trusts are not exempt! All trusts must comply with annual tax return obligations.

Sars’s 2025 guidance reiterates that no trust is legally considered “dormant,” and fiduciary obligations persist even in the absence of active trading or distributions.

A New Era of Data-Driven Compliance

Sars’s compliance strategy is underpinned by technology. By integrating data from IT3(d) and IT3(t) submissions, alongside banking, payroll, and other third-party sources, the revenue authority is positioned to automate assessments and proactively detect discrepancies.

This is part of a broader compliance program, referred to as Project AmaBillions that assumes most taxpayers want to do the right thing, but Sars is prepared to enforce the law where necessary. As such, legal instruments and data systems will be used to identify, audit, and hold accountable those who fall short of their obligations.

Don’t Leave It Until the Last Minute

The first quarter of 2025 is already behind us, and the submission deadlines for both IT3(d) and IT3(t) are fast approaching. Whether you are a trustee or manage a public benefit organisation, early and accurate compliance is essential.

Assistance from accounting, legal, and tax professionals is no longer ‘nice to have’; it’s a necessity. Engaging qualified professionals also helps streamline submissions and puts in place lasting governance and compliance frameworks.

With compliance increasingly automated and enforcement more robust, aligning your reporting practices now is the most prudent step you can take.

Written by Zasha de Lange, Manager Trust and Deceased Estate Tax Compliance at Tax Consulting SA