Beneficial ownership on the ITR14 versus CIPC

What beneficial ownership a South African company discloses on its ITR14, how SARS's approach can differ from CIPC's, and one record for both.

By Achekam · 11 October 2026 · 4 min read · For Accountants & audit firms in South Africa

The tax manager is completing a client's ITR14 and reaches the beneficial ownership section. She copies the names from the CIPC declaration the company secretarial team filed a few months ago. It seems sensible: the same company, the same owners, the same question. Except it is not quite the same question, and SARS says so itself.

South African companies now disclose beneficial ownership to two authorities, for different purposes and at different times. A firm that treats the two disclosures as interchangeable risks filing figures that do not match, without being able to explain why.

What SARS asks for on the ITR14

SARS's guide to completing the ITR14 says it requires disclosure of the beneficial ownership of a company, meaning the individuals who ultimately own or effectively control it, on every ITR14 for the 2022 tax year or later. The SARS guide to completing the ITR14 for companies sets out the requirement and the return's other sections, and is the reference for what each field means.

Two words in SARS's description do most of the work: "ultimately" and "effectively". The disclosure looks through companies and trusts in the ownership chain to the people at the end of it, and it includes people who control the company without necessarily owning its shares.

CIPC's definition

CIPC defines a beneficial owner as an individual who directly or indirectly ultimately owns or exercises effective control of a company, including through voting rights, the right to appoint or remove directors, or a chain of ownership.

CIPC's filing cycle is different from SARS's. CIPC says that from 1 July 2024 all companies and close corporations must submit beneficial ownership declarations with their annual returns, and that new entities file within 10 business days of incorporation, with an amended declaration due within 10 business days of any change. Who counts under CIPC's definition is explained in who is a beneficial owner, and the CIPC deadlines in beneficial ownership filing and update deadlines.

Why the two may not match

SARS notes that its approach may differ from CIPC's beneficial ownership requirements. That is the most important sentence for the tax manager in the opening example. Copying one disclosure into the other assumes they are the same, and SARS has said they may not be.

Differences can arise in at least three ways:

Worked in words: a family trust holds all the shares in the client. The CIPC declaration, filed early in the tax year, names the trust's two trustees and its main beneficiary. Halfway through the year, the founder's son is appointed a trustee and given the right to appoint directors, and nobody files an amended CIPC declaration. By the time the ITR14 is prepared, the people who effectively control the company are not the people on the CIPC record. Copying the CIPC names into the ITR14 would repeat the gap; the fix is to file the amended declaration and prepare the ITR14 from the current facts.

The aim is not to make the two lists identical at any cost, but to make each one right for its own purpose, and to be able to explain any difference. Read SARS's guide for its approach before completing the ITR14, rather than relying on the CIPC filing.

Collecting ownership chains from clients

Both disclosures depend on information only the client can give, and both look through layers of companies and trusts. Collect it once, properly.

In Achekam, staff can create, send and track requests to the client for documents, answers and confirmations in one RFI console. A beneficial ownership request might ask the client for:

• the current share register;
• for each corporate shareholder, its own shareholders, repeated up the chain;
• for each trust in the chain, the trust deed and the names of trustees and beneficiaries;
• any agreement that gives someone voting control or the right to appoint or remove directors;
• confirmation of any change during the tax year, with the date.

Because the request is tracked, the firm knows what has arrived and what is still outstanding when the return or the declaration falls due.

Keeping one record on the client's file

The answer to two disclosures is one well-maintained record, from which both are prepared. The record should show each beneficial owner, how they own or control the company, the dates of any changes, and the evidence for each link in the chain.

Staff can open any client's Client 360 record in Achekam, which reads the client's services, contacts, timeline and profile from the server, so it is the natural starting point when someone needs to see who the client is and who they deal with. The evidence itself belongs in the client's folder in the Document Centre, where files are versioned, tagged and searchable.

One caution: although the client directory itself is kept on Achekam's server, some sub-lists edited in place on the client record, including KYC fields, still live only in the browser. Do not keep the beneficial ownership record there, because colleagues will not see it and it can be lost. Keep the ownership schedule as a document in the client's folder, and update it whenever either filing is prepared.

Each time, prepare the CIPC declaration and the ITR14 disclosure from that schedule, and record any reason the two differ.

Before the next company return is submitted, compare its beneficial ownership disclosure with the latest CIPC declaration and with the ownership schedule. Where they differ, find out why, correct whichever is wrong, and note the explanation on the file.

General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.