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.


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