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South African Trust Tax Rates 2026: Income, CGT (36%), Dividends, Donations & Estate Duty

Every rate that drives trust and restructuring planning, in one citable table — current to 3 June 2026, with the source behind each figure.

Published Last reviewed 6 min read

Written by

Martin Kotze

Attorney, Conveyancer & Notary Public

Quick answer

The 2026 rates table

These are the rates referenced throughout the trusts hub. They are South African and time-sensitive; cite the “Last reviewed” date when quoting them.

South African trust & restructuring tax rates (current to 3 June 2026)
TaxApplies toRate (2026)
Income tax — trustIncome retained in an ordinary trust45% (flat)
Income tax — companyNewco's rental / trading profit27%
Income tax — individualIncome vested in a resident beneficiaryUp to 45% (sliding scale)
CGT — trustGain retained in an ordinary trust (80% inclusion)36% effective
CGT — companyGain in a company (80% inclusion)21.6% effective
CGT — individual / special trustGain in a person / special trust (40% inclusion)18% effective
Dividends taxCompany pays a dividend upward20%
Donations taxGifts / s 7C deemed donations (25% over R30m cumulative)20%
Estate dutyDutiable estate on death (25% over R30m)20%
Securities transfer taxTransfer of shares (e.g. Newco shares to the trust)0.25%
VATStandard-rated supplies (e.g. commercial property by a vendor)15%
Official rate of interests 7C deemed donation on low/no-interest loans (repo 7% + 1%)8% (from 1 Jun 2026)
Transfer dutyAcquiring property — sliding scale0% to R1.21m … 13% above R13.31m

Last reviewed: 3 June 2026. A special trust is taxed on the individual sliding scale (CGT 18%), not the flat 45% / 36% that applies to an ordinary trust. 2026 Budget measures are subject to Parliament’s legislative process — confirm enactment before relying on them.

Capital gains tax (the 36% point)

The single most-misstated trust figure is the CGT rate. The effective rate is the inclusion rate multiplied by the income-tax rate. SARS sets it out plainly:

Source — the actual words

The effective CGT rate on a capital gain (ignoring exclusions) is determined by multiplying the inclusion rate by the statutory rate. For the 2018 to 2020 years of assessment
— an individual in the top tax bracket would pay CGT at an effective rate of 18% (45% × 40%) (2017: 16,4% (41% × 40%);
— a company would pay CGT at an effective rate of 22,4% (28% × 80%) (2017: 22,4%);and
— a trust would pay CGT at an effective rate of 36% (45% × 80%) (2017: 32,8% (41% × 80%).

Note — The Guide’s 22,4% company figure (28% × 80%) predates the 2023 reduction of the company income-tax rate to 27% — the current company effective CGT rate is 21.6% (27% × 80%), as the live SARS rate table below confirms. The trust rate (36%) and individual rate (18%) are unchanged. SARS uses a comma decimal separator, and the unclosed brackets are reproduced exactly as printed in the Guide.

SARS Comprehensive Guide to Capital Gains Tax (Issue 9), Comprehensive Guide to CGT (Issue 9), para 3.6Read it on SARSPDF

The 22,4% company figure above is the one figure that has dated — the Guide predates the 2023 cut of the company rate to 27%. SARS’s live rate table carries the current numbers (and confirms the trust and individual rates are unchanged):

Source — the actual words

25 February 2026 – No changes in percentages but changes to exclusions (see in bold below): Type 2027 2026 2025 2024 2023 2022 Individuals and Special Trusts 18% 18% 18% 18% 18% 18% Companies 21.6% 21.6% 21.6% 21.6% 21.6% 22.4% Other Trusts 36% 36% 36% 36% 36% 36% Events that trigger a disposal include a sale, donation, exchange, loss, death and emigration. The following are some of the specific exclusions: R3 000 000 gain or loss on the disposal of a primary residence; … Annual exclusion of R50 000 capital gain or capital loss is granted to individuals and special trusts; …

Note — The 25 February 2026 note records “no changes in percentages” for 2026/27 — only certain exclusions changed. The 40% (individuals / special trusts) and 80% (companies / other trusts) inclusion rates that produce these effective rates are not stated on this page; they live in the Eighth Schedule to the Income Tax Act 58 of 1962 (para 10).

SARS Capital Gains Tax rate table, CGT rate table (effective rates, 2022–2027)Read it on SARS

So an ordinary trust’s effective CGT is 36% — twice an individual’s 18%. That gap is why the conduit principle matters so much, and why a company is sometimes preferred for an asset that will be sold at a gain.

The actual SARS words behind each headline rate

Each rate in the table above is stated here in SARS’s own words, so the figure can be cited rather than taken on trust. Plain-language summary first, then the verbatim extract.

Donations tax — 20%, rising to 25% above R30 million

A gift attracts donations tax at 20%; once your cumulative donations since 1 March 2018 pass R30 million, everything above that is taxed at 25%. The first R150 000 a natural person gives away each year is exempt. This is the rate that the section 7C deemed donation on a low- or interest-free loan to a trust is charged at.

Source — the actual words

From 1 March 2018, donations tax is levied at a rate of 20% on the aggregated value of property donated not exceeding R30 million, and at a rate of 25% on the value exceeding R30 million ( section 64(1) ). … where the donor has exceeded the R30 million threshold, all subsequent donations will be taxed at the rate of 25%. … The first R150 000 of property donated in each year of assessment by a natural person is exempt from donations tax (section 56(2)(b)).

SARS Donations Tax, “Donations Tax Rate” and “Exemptions” (Category Three)Read it on SARS

The section 7C official rate of interest — 8% from 1 June 2026

The “official rate of interest” is the repo rate plus one percentage point. With the repo rate at 7%, the official rate is 8% from 1 June 2026. It is the benchmark used to measure the interest shortfall on a low- or no-interest loan to a trust, which becomes a deemed donation — so re-check it on every repo change.

Source — the actual words

The term “official rate of interest” is defined in section 1(1) of the Income Tax Act 58 of 1962 … 01.12.2025 | 31.05.2026 | 7.75% … 01.06.2026 | Until change in Repo* rate | 8.00% … Note: The official rate of interest is linked to the Repo rate plus one per cent. The official rate is applied from the first day of the month following the date on which that new Repo rate comes into operation.

Note — The repo rate was raised to 7% effective 29 May 2026 (SARB MPC, May 2026), and the official rate is applied “from the first day of the month following” a repo change — hence 8% from 1 June 2026.

SARS Interest Rates — Table 3 (official rate of interest), Table 3, current rows (official rate of interest)Read it on SARSPDF

Dividends tax — 20%

When a company pays a dividend up to its shareholders, 20% is withheld and paid to SARS. A return of contributed tax capital is not a dividend and is not taxed.

Source — the actual words

The rate of Dividends Tax increased from 15% to 20% for any dividend paid on or after 22 February 2017 (irrespective of declaration date), unless an exemption or reduced rate is applicable.

SARS Dividends Tax, “How much will be paid?”Read it on SARS

Transfer duty — the 2026/27 sliding scale (0% to 13%)

Acquiring property attracts transfer duty on a sliding scale: 0% on the first R1 210 000, rising to 13% on value above R13 310 000. The scale that took effect 1 April 2025 is unchanged for the 2027 tax year.

Source — the actual words

Transfer duty is payable at the following rates on property transactions that are not subject to VAT. Value of Property (R) Rate 1 – 1 210 000 0% of the value 1 210 001 – 1 663 800 3% of the value above R1 210 000 1 663 801 – 2 329 300 R13 614 + 6% of the value above R1 663 800 2 329 301 – 2 994 800 R53 544 + 8% of the value above R2 329 300 2 994 801 – 13 310 000 R106 784 + 11% of the value above R2 994 800 13 310 001 and above R1 241 456 + 13% of the value exceeding R13 310 000

Note — The Budget 2026 Tax Guide’s wording and figures are reproduced exactly; the table is set out as “Value of Property (R)” against “Rate”, row by row.

National Treasury Budget 2026 Tax Guide, Budget 2026 Tax Guide — Transfer duty (1 March 2025 – 28 February 2026)Read it on National TreasuryPDF

2026 Budget changes to watch

The 2026 Budget increased the donations-tax annual exemption to R150,000 (natural persons) and the casual-gift exemption to R20,000, and limited the inter-spousal exemption to a resident recipient spouse. These are Budget measures subject to Parliament’s legislative process — use R150,000 for current planning but confirm the exact wording in the 2026 Rates and Monetary Amounts Act before relying on it. The transfer-duty scale (0% to R1.21m; 13% above R13.31m) and the CGT rates above were unchanged.

Source — the actual words

Donations tax is levied at a flat rate of 20% on the cumulative value of property donated since 1 March 2018, not exceeding R30 million; and at a rate of 25% on the cumulative value of property donated since 1 March 2018, exceeding R30 million. The first R150 000 of property donated during each tax year by a natural person is exempt from donations tax. In the case of a taxpayer who is not a natural person, the exempt donations are limited to casual gifts not exceeding R20 000 in total per tax year. Dispositions between spouses, where the recipient is a tax resident; donations between companies forming part of a South African group of companies; and donations to certain public benefit organisations are exempt from donations tax.

Note — This is a Budget 2026 measure (announced 25 February 2026), to be enacted via the 2026 Rates and Monetary Amounts and Amendment of Revenue Laws Bill — it is subject to Parliament’s legislative process. Confirm enactment before relying on the figures as law in force.

National Treasury Budget 2026 Tax Guide, Budget 2026 Tax Guide, “Donations Tax” (rates 1 March 2026 – 28 February 2027)Read it on National TreasuryPDF

Frequently asked questions

  • 36% for an ordinary trust (80% inclusion × 45%). Not 18% — that is the top individual rate. A company is 21.6% (80% × 27%); a special trust is taxed like an individual (18% ceiling). See how trusts are taxed.

  • Donations tax is 20% (25% over R30m cumulative). The natural-person annual exemption is R150,000 (up from R100,000) and casual gifts R20,000 — announced in the 2026 Budget, subject to enactment. See donations and funding.

  • Repo + 1% = 8% from 1 June 2026 (repo 7%). It drives the section 7C deemed donation; re-check SARS Table 3 on each repo change.

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Why you can trust this: Martin Kotze has been an admitted Attorney of the High Court of South Africa, registered Conveyancer, and Notary Public since 2014, practising from Pretoria. The firm is regulated by the Legal Practice Council under firm registration 17444.

This guide is general information, not legal advice for your specific matter.

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