Effective 8th December 2025, the South African Revenue Service (‘SARS’) has implemented important enhancements to the Transfer Duty Declaration (TDC01) process on eFiling. According to SARS’ release, these changes are aimed at simplifying compliance, reducing inaccurate declarations, and improving the collection of tax revenue by addressing tax gaps during property transactions.
Critically, the amendments introduce stricter validation requirements for sellers and purchasers and will directly affect how conveyancers prepare and submit Transfer Duty Declarations.
Mandatory tax reference numbers
One of the most significant changes is the requirement that a tax reference number must now be provided for both sellers and purchasers in transfer duty submissions.
For individuals, this requirement applies to transactions where the total fair value exceeds R2 million. In such cases, the individual’s income tax number must be included in the TDC01 submission.
For juristic entities, including companies and close corporations, income tax numbers are required, subject to limited recognised exceptions, such as certain government and related entities.
Where a required tax number is not provided, SARS’ enhanced validation system may reject the submission, potentially delaying the issuing of the Transfer Duty Receipt and, in turn, registration at the Deeds Office.
Removal of the annual income field
Notably, SARS has now removed the annual income field from the TDC01 form. This field is no longer visible or applicable.
The removal reduces reliance on self-declared income information in the transfer duty process and aligns the declaration more closely with SARS’ existing tax registration records. Practitioners should ensure that internal precedents and data capture processes are updated accordingly.
Foreign residents
While SARS’ December 2025 announcement does not create a separate regime for foreign parties, the enhanced validation requirements apply equally to foreign sellers and purchasers.
Operational implementation of the updated TDC01 process (as reflected in conveyancing platform updates) indicates that foreign individuals must comply with strengthened taxpayer identification requirements. Where a foreign individual purchaser is not registered for South African income tax, the ‘Not registered for income tax’ functionality may be utilised, subject to the required reason selection.
These enhancements form part of SARS’ broader compliance focus on accurate taxpayer registration and identification in property transactions, including those with cross-border elements.
New ‘not registered for income tax’ field
SARS has introduced a new ‘Not registered for income tax’ field in the TDC01, applicable only to individual purchasers. Where selected, a reason must be chosen from a prescribed list.
The option is relevant only where the total fair value of the transaction does not exceed R2 million. Above that threshold, an individual’s tax reference number must be provided.
From a practical perspective, operational implementation within conveyancing platforms indicates that the available reasons include:
- Minor
- Unemployed
- Earning under the income tax threshold
- Divorce order
- Foreign individual
The system further records a warning that a false declaration may constitute a criminal offence under sections 234 and 235 of the Tax Administration Act.
Addition of ‘Divorced’ as a marital status
The TDC01 form now includes ‘Divorced’ as a specific marital status option.
Previously, divorced individuals were often captured as ‘Unmarried’, which could create inconsistencies between the Transfer Duty Receipt and other transactional documentation. The inclusion of this option allows for more accurate recording of parties’ marital status and should be carefully reflected in supporting documentation.
Enhanced validation controls
SARS has introduced enhanced system validations within eFiling and integrated conveyancing platforms to reduce the submission of inaccurate or incomplete information.
These validations include:
- Mandatory verification of tax reference numbers where required;
- Enforcement of the R2 million threshold for individuals;
- Mandatory completion of the ‘Not registered’ reason where applicable; and
- Stricter validation of juristic entity details.
Non-compliant submissions may be rejected, which could lead to delays in obtaining the Transfer Duty Receipt and potentially impact registration timelines.
Practical considerations
For parties involved in property transactions, early verification of tax registration status is now essential. To that end, conveyancers should obtain tax reference numbers at the outset of a transaction, confirm marital status accurately, and ensure that any reliance on the ‘Not registered’ option is properly supported, among other requirements. Intended to tighten compliance in property transfers, SARS’ revised transfer duty-centred requirements demand proactive preparation to avoid delays and ensure seamless registration.
For further information or expedient assistance with income tax registration, contact our team of property law attorneys.
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