Reference & tools

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

For 2026: an ordinary trust pays income tax at a flat 45% and CGT at an effective 36%; a company 27% / 21.6%; an individual the sliding scale / 18%. Dividends tax is 20%, securities transfer tax 0.25%, VAT 15%, estate duty 20% (25% over R30m), donations tax 20% with a R150,000 annual exemption (2026 Budget), and the section 7C official rate of interest is 8% from 1 June 2026.

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. … an individual in the top tax bracket would pay CGT at an effective rate of 18% (45% × 40%); a company would pay CGT at an effective rate of 22,4% (28% × 80%); and a trust would pay CGT at an effective rate of 36% (45% × 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%). The trust rate (36%) and individual rate (18%) are unchanged.

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

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.

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.

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.

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 F17333.

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

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Martin Kotze drafts trust deeds, registers trusts with the Master, and structures trust-and-company holdings end-to-end. General guidance on this page is not a substitute for advice on your facts.