Tax Exempt Institutions Connect Issue 9 (September 2025)

Issue No 9 (September 2025)

This issue discusses the compliance requirements for income tax exempt institutions and key compliance requirements for trusts that are approved Exempt Institutions (EI). It covers the trust-return submission periods and IT3(d) and IT3(t) submission and the updating of registered details.

We also offer tips when sending emails to SARS and stress the importance of using the services of registered tax practitioners.

Trust Tax Filing Season
Key Dates for Trust Tax Matters
Submission of Annual Returns
Updating Registered Details
Top Tips for Sending Emails to SARS
Tax Exempt Institutions and Tax Practitioners

Trust Tax Filing Season

Exempt Institutions (EI) trusts must meet all the requirements set out in the applicable sections of the Income Tax Act (ITA). A Public Benefit Organisation (PBO) that is a trust must meet the requirements of Section 30 of the ITA, as well as the requirements set out for trusts. These requirements include the submission of annual returns (IT12EI) during the Trust Filing Season, plus IT3(t) and IT3(d) returns where applicable.

The Trust Filing Season for the 2025 tax year runs from 20 September 2025 to 19 January 2026 for all trusts (including EI Trusts). Trustees or their representatives must file an accurate Income Tax Return for EI trusts (IT12EI) on eFiling to comply with the Income Tax Act of 1962.

IT3(t) returns for trusts, which declare amounts vested to beneficiaries’ income, are due by 30 September 2025.

Importance of Compliance

Trusts play a vital role in the tax system. Timely and accurate submission of trust returns is not only a legal requirement; it also strengthens the integrity of the tax base.

Trusts Can Manage Their Taxes Online

Register new trusts for income tax using the SARS Online Query System (SOQS). This applies to both resident and non-resident trusts (that earn South African income), whether active or passive.
Register the trust for eFiling.

You can also watch the informative videos on trusts below:

Submission of Annual Returns

All Income Tax Exempt Institutions must submit annual returns (IT12EI) for non-profit companies, trusts, and other exempt institutions.

The submission dates of annual returns are:

Trust Filing Season: 19 September 2025 to 19 January 2026.
Non-profit companies and other EIs: within 12 months after the entity’s elected financial year-end.

SARS has developed a five-part series of micro-learning videos on how to complete and submit the IT12EI returns to SARS via eFiling. The links to these educational micro-learning videos are available at the end of the newsletter.

Consequences of Non-Compliance

Entities that are non-compliant cannot provide their donors/funders with a compliant Tax Compliance Status, which may affect their ability to attract funding. Non-compliant entities can be subject to administrative penalties for outstanding returns or interest on outstanding debt. Failure to comply may lead to the withdrawal of the taxpayer’s exemption status.

Non-compliance as an Income Tax Exempt Institution may include:

Non-submission of annual (outstanding returns) to SARS.
Debt due to SARS.
Non-compliance with exemption requirements and other reporting requirements.

In addition, if the EI is an approved Section 18A entity, all receipts issued must contain all the required information per regulatory requirements. Otherwise, SARS will reject the deduction claim. Approved S18A entities must also submit IT3(d) third-party data during the bi-annual (30 October) and annual (31 May) submission periods.

Note: if SARS withdraws an entity’s exemption status because of non-compliance, the entity becomes a normal taxpayer with the associated tax liabilities and obligations. If an entity’s Section 18A status is revoked, donors cannot claim the tax deduction.

Please refer to the Compliance Fact Sheet for more information on how to update the registered particulars of the EI.

Key Dates for Trust Tax Matters

20 September 2025: opening date for IT12EI (trust) submissions.
30 September 2025: deadline for IT3(t) for trusts which declare amounts vested to beneficiaries’ income.
30 October 2025: deadline for IT3(d) for trusts that are approved as Section 18 entities.

The appointed representative taxpayer (trustee or tax practitioner) must submit the IT12EI annually within the prescribed trust-return filing period through SARS eFiling.

Keep the Registered Details of the Entity Updated with SARS

All EIs should update SARS of any changes to the registered details within 21 business days. These registered particulars may include:

Registration details (e.g. registered/trading name changes)
Registered representative changes
Physical or postal address changes
Contact numbers
Email address
Bank account details
Financial year-end changes
Office bearers or fiduciary-responsible persons changes

Update the above registered details through:

SARS eFiling
SARS Online Query System
Escalation of cases (with case number) emailed to [email protected]

Top Tips for Sending Emails to SARS

Emails sent to SARS with attachments that include embedded or clickable links, macros, or scripts are often flagged as harmful. Even if the document appears legitimate, these features can be exploited by attackers.

Common triggers include:
- PDF or Office documents containing hyperlinks to external websites.
- Password-protected or encrypted attachments that cannot be scanned.
- Executable files or uncommon file types.

Senders should check that attachments are plain documents without embedded links whenever possible. If links must be included, provide them in the body of the email rather than inside a PDF; this is safer and less likely to be blocked.

Recommended Actions for the Sender

Upload supporting documentation on SOQS.
Include the organisation name, Income Tax Reference Number (if applicable), and case number (if applicable).
Avoid embedding hyperlinks inside attachments; rather, provide references in the email body.
Where possible, submit attachments in standard formats (e.g. simple PDFs without encryption or scripting).
If a particular file is consistently blocked despite appearing safe, senders can contact SARS to ask for alternative submission methods.

This approach will help reduce the likelihood of legitimate messages being blocked, while protecting the organisation from harmful content.

For more information on how to contact SARS view Contact SARS by email/online.

SARS Warns against Using Unregistered Individuals to Provide Tax Services

Exempt Institutions should contract the tax services only of legitimate and registered practitioners. Always check that a tax practitioner is registered with SARS and a Recognised Controlling Body. A registered tax practitioner is paid to administer the tax affairs of the EI, such as applying for EI status on the entity’s behalf; completing and submitting annual income-tax returns (IT12EI); and submitting IT3(d) third-party data. The EI’s tax practitioner can also provide services to the EI free of charge (pro bono).

Note: pro bono services do not qualify for a Section 18A tax deductible receipt.

To confirm a practitioner’s registration, click here.