IT3(d) Third Party Data FAQs

---

IT3(d) Third Party Data FAQs

• 28 May 2024
• Tax Update
• SARS

Please Note: IT3(d) onboarding, testing and live submissions will remain open for the duration of the submission period. Organisations are encouraged to submit the available data. These organisations will still be able to submit additional information after the submission period. 

For the latest BRS please click here.

The eFiling guide is available here.

The HTTPS guide is available here.

The manage IT3(d) submissions guide is available here.

Should your organisation experience any technical or system related problems, please send an email to 3rd Party Data Support (Bus_Sys_CDSupport@sars.gov.za).

---

Which S18A Entities are Required to Submit IT3(d) Third Party Data to SARS

• Scenario 1: Approved EI but no S18A status – Not required to submit IT3(d).
• Scenario 2: Approved EI with S18A status BUT DID NOT issue tax deductible receipts – Required to submit IT3(d) – Null Declaration in terms of BRS.
• Scenario 3: Approved EI with S18A status AND issued tax deductible receipts – Must submit IT3(d) data of receipts issued – compulsory by law.

---

Legal and Policy FAQs

Does the Submission of 3rd Party Data Impact on All Exempt Institutions /PBOs?

No, 3rd party reporting will only affect the Tax Exempt Institutions according to their various registration capacities. For example:

• Certain employers must register for Pay-As-You-Earn and submit their payroll data;
• Certain Trusts will, in future, be required to submit IT3(t) certificates relating to amounts vested in beneficiaries; and

Approved section 18A institutions must make IT3(d) submission in relation to section 18A tax deductible receipts issued (Null Declaration where no receipts were issued)

What Tax Year is the First Submission Connected to?

Third party reporting is not connected to any year of assessment belonging to the donor or approved section 18A entity, but relates to the following periods stated in the Public Notice:

• 1 March to the last day of February of the following year (for submissions due by 31 May of each year).
• 1 March to 30 September (for submissions due by 31 October of each year).

Therefore, the first compulsory submission due by 31 May 2024 relates to information for all receipts issued in the period 01 March 2023 to 29 February 2024.  

When is the Data Due to SARS?

By 31 May 2024 – the channel for submission is already open for those wanting to submit before the due date.

Is This Mandatory for This Year’s Submission?

Yes, all section 18A approved institutions are required by law to prepare and make IT(d) submissions to SARS on the dates published in the Public Notice:

• 1 March to the last day of February of the following year (for submissions due by 31 May of each year).
• 1 March to 30 September (for submissions due by 31 October of each year).

Therefore, the first compulsory submission due by 31 May 2024 relates to information for all receipts issued in the period 01 March 2023 to 29 February 2024.

Who is Responsible to Submit it to SARS?

By the S18A approved entity itself, or by an Accountant / tax practitioner or a service provider.

What are the Implications to Your Entity if You Do Not Submit this Data to SARS?

The approved institution will be non-compliant with the requirements of the law and may be exposed consequences such as:

• Penalties levied by SARS;
• Reputational damages or loss of donor support due to donors being routed for audit and not being able to obtain section 18A deductions timeously; or
• Overall non-compliant tax clearance status.

What are the Implications to Your Donors if You Do Not Submit this Data to SARS?

Donors will be subjected to an audit or other verification process and will not be able to enjoy the required deduction in a timely manner e.g. delayed refunds, etc.

My Organisation Issues an Annual Donation to Regular Donors as Opposed to a Monthly Receipt.  Is This Correct?

A single section 18A receipt issued to a single donor taxpayer is acceptable for purposes of section 18A and the requirements relating to third-data reporting. The section 18A receipt must meet the mandatory requirements of a valid section 18A receipt and, most importantly, must contain a breakdown of the individual cash and non-cash donations received and the dates of receipt of such donations.

Please note: The submission of a Null declaration mitigates the risk of fraudulent claims i.e. using the section 18A approved EI’s details to make false submissions, thereby facilitating fraudulent claims. The simplified process. Taxpayers wishing to submit only Null Declaration may do so via eFiling, where it is not required to create a Registered Representative, Technical Administrator and Technical User. An eFiling registered user only has to activate IT3 as a tax type and complete the IT3(d) form.

---

Technical FAQs

What is IT3(d)?

IT3(d) is the third party data approved Section 18A entities are required to submit to SARS. This data includes all the S18A tax deductible receipts issued to donors during the period from 01 March 2023 to 29 February 2024.

Which Browser Can be Used for Third Party Data Submission?

See the Browser compatibility Guidelines.

What is the Difference Between IT3(d) and IT3(t)?

It3(d) is the submission of third party data by approved Section 18A entities. This third party data submission specifically relates to the Section 18A tax deductible receipts issued (as per the Public Notice 3082 of the Government Gazette 48104 on 24 February 2023 and Public Notice 3631 published in Government Gazette No. 48867 on 30 June 2023).

IT3(t) is the submission of demographic information of the reporting Trust and Trust Person / Beneficiaries. The IT3(t) also requires information relating to the taxable amounts distributed / vested in Persons / Beneficiaries, details of non-taxable income distributed and Trust financial flows (as per Public Notice 3631 published in Government Gazette No. 48867 on 30 June 2023).

Will the IT3(d) Process Also be Available for Submission on E-Filing?

Yes. Approved Section 18A entities will be able to submit up to 50 receipts per reporting entity (approved S18A entity). 

How Does my Entity Activate IT3(d) on eFiling?

SARS has developed a micro-learning video on how taxpayers can activate IT3(d) third part data submissions. The micro-learning video is available on the SARS TV YouTube channel or can be access directly by clicking on this link IT3 Tutorial Micro Video.

Please note: Approved Section 18A entities are required to be registered on eFiling; and have the registered representative updated on eFiling as this will be the person submitting the IT3(d) on behalf of the entity. 

How Does my Entity Enrol for IT3(d) on eFiling?

SARS has developed a micro-learning video on how taxpayers can activate IT3(d) third part data submissions. The micro-learning video is available on the SARS TV YouTube channel or can be access directly by clicking on this link IT3 Tutorial Micro Video.

Please note: Approved Section 18A entities are required to be registered on eFiling; and have the registered representative updated on eFiling as this will be the person submitting the IT3(d) on behalf of the entity.

Is IT3(d) a Form That a Reporting Entity Submits on eFiling?

Yes, it is called IT3-01.

What Does the Error Messages Received on HTTPS Files Submitted to SARS Mean?

Error messages in response to submissions can be interpreted in view of the following aspects available in the IT3 External BRS:

• For each data entry the following attributes are listed:
  • Type and Condition Rule entry
  • Data Type
  • Length Type
  • Length
  • Data Validations
  • Logic Validations
• Appendix H – File Response Codes
• Appendix M – Response Codes

Each response line (see Section 6.6 in the External BRS) will contain reference to the items listed above.  It will also point to the specific line and item in the submission.

Note that the response file contains the following items:

• Request / Response File Header
• Request / Response File Body
• Request / Response File Trailer

How do I Know if the Entity’s Submission Has Been Successfully Submitted to SARS?

One of the following options would be visible in the File Response Code item:

• 003 – Successfully uploaded: all records accepted and processed.
• 04 – Accepted with warnings: This can be any combination of accepted fields, fields accepted with a warning and duplicate records.
• 006 – Partial upload: This can be any combination of accepted fields, rejected fields, fields accepted with a warning or duplicate records.

As a Tax Practitioner or Service Provider do I Have to Have Multiple HTTPS Certificates (Per Client) with SARS?

No A tax practitioner / service provider does not have to have multiple HTTPS certificates per client. The tax practitioner / service provider’s HTTPS will be the one used to submit for all their clients.

What are the Three Roles to Submit Using the HTTPS Channel?

The roles are:

• Business Administrator – This user is the same as the current eFiling full administrator. The role of this user is to enrol the legal entity/organisation that will be submitting data to SARS and the Technical Administrator.  The taxpayer is not required to allocate new eFiling administrators for the purposes of third-party data submissions if one already exists.
• Technical Administrator – The role of this user is to request the security certificate and to enrol technical users. If the taxpayer decides to change the Technical Administrator, a new Technical Administrator must be added before the existing one can be removed.  There must always be at least one Technical Administrator for each enrolled organisation.
• Technical User – The role of this user is to submit the data files to SARS via the Direct Data Flow channel. An organisation can have multiple Technical Administrators and Technical Users to allocate work according to the organisation’s requirements.  The Technical User must be a different person from the Technical Administrator.

Also view the detailed discussion per SARS guide: GEN-ENR-01-G02 – Guide for Submission of Third Party Data Using the HTTPS Channel – External Guide

What is the Role of the eFiling Business Administrator?

This user is equivalent to the current eFiling full administrator. The role of this user is to enrol the legal entity/organisation that will be submitting data to SARS. Thus user must also select the technical Administrator (TA) that will complete the enrolment process.

What is the Role of the Technical Administrator Details?

The role of this user is to request the digital certificate and to select/appoint technical users.

What is the Role of the Technical User?

The role of this user is to submit files.

Can One Person Have More Than One of the 3 Roles?

No. Each role has to be given to different people.

Can a Submitting Entity or Reporting Entity Submit Multiple Files via HTTPS (Due to Errors, Partial Uploads etc)?

Yes, and at the end of a reporting period they all get declared (accepted) by submitting the IT3-02 form.

Can a Submitting Entity or Reporting Entity Submit Multiple Files via eFiling (Due to Errors, Partial Uploads etc)?

Yes, and it is important to note that the multiple use of IT3-01 forms is possible:

• An eFiling IT3-01 forms User can submit an unlimited amount of IT3-01 forms per tax year.
• A maximum form certificate limit is applicable per single IT3-01 form. g. a maximum of 50 certificates is allowed per IT3-01D form.
• For saved forms on eFiling (i.e. work-in-progress – un-submitted) the limit is 12 at any specific time.
• This means that a Submitting Entity don’t have to enrol each of its clients for a unique submission per client but can do it under their own enrolment.”

If the Approved S18A Entity is Experiencing Poblems on Enrolling for IT3(d) on eFiling who Dhould They Contact?

They should direct their inquiries to 3rd Party Data Support at Bus_Sys_CDSupport@sars.gov.za.

If the Approved S18A Entity is Experiencing Problems with the Submission of IT3(d) Data on HTTPS, Who Should they Contact?

They should direct their inquiries to 3rd Party Data Support at Bus_Sys_CDSupport@sars.gov.za.

May an Approved S18A Entity Use More Than One Submission Channel?

Yes, a Submitting Entity can use multiple channels for the same submission period. The IT3-02 declaration will summarise all the information from these channels in one document to be declared.

Is the Tax Reference Number for Donors Mandatory for the Submission of IT3(d) Data to SARS?

No, Field 414 in the External BRS is marked as Conditional with Warning (CW) which means SARS intend to mandate it in future and the condition is already provided. If this data is not supplied now a warning would be issued but the date line will be accepted.

May an IT3(d) Submitting Entity Use Live Data to Test on HTTPS?

Yes, they may use live data to test and once that test file was successfully accepted, they may update it with the Production Source Identifier and change Test Data Indicator from ‘T’ to ‘L’ for Live submission and submit this to Production.

---

Section 18A Entity (Reporting Entity) FAQs

Does the Entity Have to Submit an IT3(d) Even if no S18A Receipts Were Issued?

If an approved Section 18A entity that has not issued any S18A receipts for the period, is required to submit Null Declaration. Taxpayers wishing to submit only Null Declaration may do so via eFiling, where it is not required to create a Registered Representative, Technical Administrator and Technical User. An eFiling registered user must only activate IT3 as a tax type and complete the IT3(d) form.

Please note: The submission of a Null declaration mitigates the risk of fraudulent claims i.e. using the section 18A approved EI’s details to make false submissions, thereby facilitating fraudulent claims. The simplified process.

Which Submission Channel Can my Entity Use if We Issued 50 and Less S18A Receipts?

If an approved Section 18A entity has issued 50 or less Section 18A tax deductible receipts, the IT3(d) third party data can be submitted via eFiling.

Please note: Approved Section 18A entities are required to be registered on eFiling; have the registered representative updated on eFiling as this will be the person submitting the IT3(d) on behalf of the entity; and have activated / enrolled for IT3(d) on eFiling.

Which Submission Channel Can my Entity Use if We Issued 51 and More S18A Receipts?

If an approved Section 18A entity has issued 51 and more Section 18A tax deductible receipts, the IT3(d) third party data can be submitted via HTTPS. The HTTPS channel allows for the submission of 50MB files or 50 thousand lines.

Please note: Approved Section 18A entities are required to be registered on eFiling; have the registered representative updated on eFiling as this will be the person submitting the IT3(d) on behalf of the entity; and have activated / enrolled for IT3(d) on eFiling.

How Can the Entity Update the Registered Representative on eFiling?

An approved Section 18A entity can visit the Registered Representative webpage on how to update the entity’s registered representative.

Is the Updating of the Registered Representative Mandatory for the Submission of IT3(d) Data to SARS?

Yes. The entity will not be able to submit IT3(d) data if the registered representative is not up to date.

Is the Updating of the Registered Representative Mandatory for the Submission of IT3(d) Data to SARS?

Yes. The entity will not be able to submit IT3(d) data if the registered representative is not up to date. 

Can More Than One Person in the Entity Submit IT3(d) Third Party Data to SARS?

Yes, the entity can identify persons responsible to submit files via the HTTPS using the provided username and password.

If my Donors Donate Monthly / by Debit Order do Have to Issue S18A Receipts Per Donation?

The entity can either issue monthly S18A receipts or a receipt with the total annual amount for the year of assessment.

If the Approved S18A Entity Has Not Issued Tax Deductible Receipts During the Year of Assessment (01/03/2024 – 29/02/2024) is it Still Required to Submit IT3(d) Third Party Data?

Yes. Even if the entity has not issued any S18A tax deductible receipts they must do a Null Declaration on eFiling.

How Often Does an Approved S18A Entity Have to Submit IT3(d) Data to SARS?

Approved Section 18A institutions are required by law to prepare and make IT(d) submissions to SARS bi-annually, on the dates published in the Public Notice:

• 1 March to the last day of February of the following year (for submissions due by 31 May of each year)
• 1 March to 30 September (for submissions due by 31 October of each year)

---

SOURCE: SARS

0 COMMENTS

LEAVE A COMMENT