On 8 September 2026, the South African Revenue Service (SARS) published its 2026 Trust Income Tax Season updates, introducing the use of third-party reporting data to pre-populate information on trusts’ tax returns as one of the most significant developments for trust tax compliance.

The trust filing season open on 19 September 2026 and closes on 22 January 2027 for both provisional and non-provisional trust taxpayers.

While there are several changes to the Income Tax Return for Trusts (ITR12T), using IT3(t) data to pre-populate information on the ITR12T, stands out.

IT3(t) reporting requires trusts to report prescribed information to SARS, including amounts vested in beneficiaries. Until now, it has largely operated as a separate third-party reporting obligation, with the data reported being used by SARS for risk assessment and analysis. 

From the 2026 tax season, this takes an important step forward as IT3(t) information will begin feeding directly into the trust’s own ITR12T and, ultimately, into the information used in assessing the trust and its beneficiaries.

In practical terms, SARS is bringing the two reporting processes closer together.

SARS said the update of the trust income-tax return process for the 2026 season, is part of the tax authority modernising its services to make it easier for taxpayers to meet their obligations and to support voluntary compliance.

Accuracy of IT3(t) Data Now Even More Important

For the 2026 tax season, SARS has confirmed that, where IT3(t) information is available:

• income, vested amounts and certain expense information will be pre-populated on the ITR12T to reduce duplication and improve accuracy; and
• beneficiary schedules will be pre-populated using information reported through IT3(t).

This means that information reported to SARS during the IT3(t) reporting cycle can effectively become the starting point for completing the trust’s income tax return.

This is more than an administrative convenience. It strengthens SARS’s ability to compare the information reported across the trust, its beneficiaries and the underlying third-party data available to SARS.

For trustees, tax practitioners and trust administrators, the accuracy of the IT3(t) submission consequently becomes even more important.

Amounts vested in beneficiaries should be supported by the trust’s accounting records and the appropriate trustee resolutions, while the treatment ultimately reflected in the ITR12T should be consistent with the information already reported through IT3(t).

Where these records do not align, the discrepancy may become considerably easier for SARS to identify.

Importantly, the IT3(t) remains a separate reporting obligation, with the 2026 IT3(t) third-party data return due by 30 September 2026.

Section 25B Comes into Sharper Focus

The 2026 ITR12T will also introduce new containers aimed at determining and analysing the impact of section 25B(4) - (6) of the Income Tax Act.

These provisions deal with the limitation of losses where expenses or deductions relating to trust income exceed the income available. Importantly, a trust cannot simply pass a tax loss on to a beneficiary.

Read together with the increased use of IT3(t) information, this points to greater scrutiny of amounts flowing through trusts to beneficiaries and the tax treatment applied to those amounts.

Trustees should accordingly not view beneficiary distributions, accounting, IT3(t) reporting and the annual income tax return as separate compliance exercises but as part of the same reporting chain.

The underlying accounting records, trustee resolutions, IT3(t) submission and ITR12T should tell the same story.

Other Changes Trustees Should Take Note Of

SARS has announced several further enhancements for the 2026 trust tax season.

Trust taxpayers will be able to amend an incorrect Master’s reference number directly on the ITR12T, subject to validation against SARS registration information. The existing field-length restriction will remain for now, with SARS indicating that a future enhancement will accommodate the full reference number reflected on the Letters of Authority.

Continuous-save functionality will also be introduced on the ITR12T, meaning information captured while completing the return will be saved automatically.

Other changes include:

• enhanced beneficial-ownership questions where a founder is a legal entity that no longer exists or a deceased natural person;
• improved special-trust qualification questions, including confirmation that the trust continued to meet the relevant requirements during the year of assessment;
• SARS aligning the ITR12T filing process with the annual Government Notice to ensure it correctly recognises which trusts fall within the legal filing population, including all registered resident trusts and qualifying non-resident trusts required to file under that notice; and
• mandatory tax-practitioner contact details.

Collective Investment Scheme trusts will also be given the option of providing beneficial-ownership information, although completion will not be mandatory.

What Changes in Practice?

It is clear that trust compliance is becoming increasingly data-driven and interconnected. Information submitted through one SARS reporting channel is no longer necessarily confined to that submission.

For the 2026 filing cycle, trustees and their advisers should pay particular attention to:

• whether beneficiary vestings and distributions are properly supported;
• whether trustee resolutions agree with the accounting treatment applied;
• whether income and expenses have been correctly classified;
• whether the IT3(t) information submitted to SARS agrees with the final accounting records; and
• whether the ITR12T ultimately agrees with the information already reported through IT3(t).

The sequencing is important too. Errors identified only when completing the ITR12T may originate in information already reported to SARS through IT3(t).

SARS is Connecting the Dots

While the 2026 trust tax season brings a number of changes, the move to use IT3(t) data to pre-populate the ITR12T is the most significant. 

It shows SARS making increasingly sophisticated use of the data already at its disposal –

connecting third-party data with the questions and information reported on the tax return and applying its risk engines across these different data points.

IT3(t) should therefore no longer be approached as an isolated annual compliance exercise. It is becoming part of the broader data picture against which the trust’s tax position is reported, tested and assessed.

For trustees, this raises the importance of getting the accounting, resolutions and beneficiary reporting right before the IT3(t) submission is made.

Trusts are entering a filing season where SARS already holds more of the information that will appear on the return and is actively using it. The 2026 filing season is therefore as much about completing an annual return, as it is about ensuring that what is filed stands up against the information SARS already has.

Written by Roxshanna du Toit, Head of Trusts at Tax Consulting SA