Application of Attribution Rules for Trusts

Date: Jun 18, 2024 - Jun 18, 2024

CPD hours: 2 Hours

Time: 15:00 - 17:00

Event Type: Webinar

Presenter: Cheryl Howard

Attribution Rules, Deeming Provisions, and Anti-Avoidance Provisions all reference this topic.


Attribution Rules, Deeming Provisions, and Anti-Avoidance Provisions all reference this topic. This is probably the most misunderstood tax clause for both tax practitioners and trust accountants when computing the tax charge, determining the appropriate taxpayer, and accounting for it in the trust’s Annual Financial Statements. Section 7 overrides the provisions of Section 25B, making the attribution rules the primary compulsory rule. Benefits accrued or deemed to have accrued to the donor or funder in terms of donations or interest-free or soft loans (lower than market-related interest rates) must be calculated and attributed to the donor or funder before any other vesting or distributions to beneficiaries.

Webinar Content

  • The rationale behind the introduction and development of the Attribution Rules.
  • Determining when to apply the Attribution Rules versus other sections affecting trust taxation, namely Section 25B and Section 26A.
  • Defining the meaning of donation, settlement, or other disposition.
  • Determining the taxpayer to whom the Attribution Rules apply.
  • The implications and applications of Sections 7C and 7D.
  • A review of each Section 7 Attribution Rule, including the definition, application, and implication of each section.
  • A review of each capital gains provision (Paragraphs 68 to 72 of the Eighth Schedule), including the definition, application, and implication of each section.
  • Examples and computations for each of the Section 7 and Paragraph 68 to 72 of the Eighth Schedule sections.
  • Examining the accounting treatment of the Attribution Rule in the trust’s Annual Financial Statements.
  • Disclosure of the Attribution Rule in the Annual Return of Income.

Competencies Developed in this Webinar

  • Understanding the rationale for the introduction of the Attribution Rules.
  • Knowing under what circumstances the Attribution Rules apply.
  • Identifying to whom the Rules apply.
  • Understanding each of the Section 7 sections and Eighth Schedule paragraphs affecting trusts, and how to compute the applicable tax.
  • Understanding the disclosure of the Attribution Rules in the Annual Return of Income for the relevant taxpayers.


Cheryl Howard 

Cheryl Howard qualified as a Chartered Accountant at Deloitte. Her professional career remained with Deloitte and Kessel Feinstein (now SNG Grant Thornton) in their respective Private Client tax departments. In 1994 she joined BoE Private Bank, managing the Private Client, Deceased Estates and Fiduciary businesses for the Johannesburg office. 

In 2000 she formed her own multiple family office practice, focusing solely on high-net-worth clients, attending to the administration of their tax, estate planning and fiduciary requirements. 

Cheryl sold her business in 2018 to an international fiduciary company, managing their South African office until the end of 2020. After an almost three-year sabbatical, Cheryl has re-commenced her Family Office Practice with the same professional service offerings as before, with a small team of professionals.

She is also involved in various coaching and training projects within the family office, tax and accounting, and fiduciary sectors. Using her 30 odd years’ experience in high-net-worth client consulting and client relationship management to develop teams and professionals wanting to specialise within family office planning and the high-net-worth client. Sharing practical experiences and family planning stories while giving the professional a practical toolkit to build upon their technical studies. Basically to nurture and refine the consultant to be client centric while providing best advice.

Cheryl has both presented on and written articles for various professional bodies, media and journals on family office planning and its dynamics. She has appeared on TV and radio discussing various aspects of estate, tax, and financial planning.

She has been a past Board member of the Fiduciary Institute of Southern Africa (FISA) and Society of Tax and Estate Practitioners (STEP) as well as a task team member on various SARS / Treasury projects.


Attending this webinar and the successful completion of the online assessment will secure a certificate of completion for 2 hours of Tax CPD.

Event Investment

Free for Tax Practitioner, Tax Accountant CPD subscribers and Practice Packages. Not a CPD subscriber yet? Click here to register now.

  • Regular price: R460.00 
  • SAIT member special discounted rate: R368.00 
  • Group booking discounts available when you register for a group.

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