SARS Ruling on Tax Treatment of Employee Share Incentive Trust Funding and Share Vesting

The South African Revenue Service (SARS) published Binding Private Ruling 429 (BPR 429) on 14 August 2026 concerning the income tax and capital gains tax treatment of cash grants made by an employer to an employee share incentive trust, the receipt of those grants by the trust, and the subsequent vesting of shares in qualifying employees.

The ruling concerns a South African resident company, eight resident subsidiaries, and a resident discretionary trust established for a long-term forfeita…