RVN Chartered Accountants Incorporated

Trusts – Conduit Principle

A recent decision by the Supreme Court of Appeal (SCA) in the case of Commissioner, SARS v Thistle Trust [516/2021][2022] ZASCA 153, had far-reaching implications for structures involving the layering of trusts and essentially, the continued application of the “conduit principle” or “look-through principle”.

In this case, the conduit principle has been rendered inapplicable to a trust which acts as both a beneficiary of another trust and receives a capital gain from it.

 

While every reasonable effort is taken to ensure the accuracy and soundness of the contents of this publication, neither writers of articles nor the publisher will bear any responsibility for the consequences of any actions based on information or recommendations contained herein.  Our material is for informational purposes and should not be construed as financial advice.

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