Important:
This answer is based on tax law for the tax year ending 28 February 2020.
Answer:
We accept that both companies, the one declaring the dividend and the beneficial owner of the dividend, are resident in the RSA for tax purposes.
Such a dividend will then, accepting that the required declarations were made to the company (see section 64G), be exempt from the dividends tax - see section 64F(a) of the Income Tax Act.
Section 64F makes no provision for a dividend to be exempt from the dividend tax where the beneficial owner is a trust (Resident or otherwise).