Partnerships Must File the IT3(BO) Before Completing ITR12 Returns
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SARS has issued a fresh stakeholder notice setting out exactly how the new Partnership Beneficial Owner declaration, the IT3(BO), fits into the personal income tax flow. This is the form that finally fixes the 2024 nightmare, where every partner had to manually capture every other partner's details on their own ITR12.
As we covered in Partnership IT3(BO) to Solve Filing Nightmare, the form lets the partnership submit those details once, centrally. The partners' ITR12s then pull from the IT3(BO) instead of each partner chasing nine other tax numbers. The new notice locks down four points.
IT3(BO) first. Always. Taxpayers must submit the IT3(BO) before the related ITR12. SARS systems use the IT3(BO) to pre-align third-party data with each partner's individual return. Skip it, and the ITR12 has nothing to validate against.
The form runs on a year cycle. The applicable year steps up every 1 April, the same way SARS handles other third-party data submissions. Pick the correct year when you submit or update. Wrong year, wrong return, hours wasted.
No deadline, no penalty (for now). The IT3(BO) can be completed, updated, and submitted at any point during the year, and SARS confirms no penalties are currently linked to its timing. That sounds relaxed. It is not. The risk sits with the partners' ITR12 returns, which won't process cleanly if the IT3(BO) is missing or outdated.
Update whenever the partnership changes. New partner joins. Existing partner leaves. Profit-sharing percentages shift. Update the IT3(BO) the moment you know, not in July.
Why This Matters for Your Practice
SARS has handed practitioners a small operational gift. The work that used to be repeated nine times for a ten-partner firm is now done once. But the gift only works if you sequence the work correctly. If you have partnership clients, this is also a clean opportunity to package the IT3(BO) submission as a separate billable line, not as part of "tax season chaos". You are doing the compliance work, you may as well charge for it visibly.
What to Do This Week
List every partnership client. Don't guess, pull the list.
Confirm the correct partnership representative is set up on eFiling for each one.
Collect partner details once: ID number, tax reference number, email, cellphone, profit-share percentage.
Submit the IT3(BO) for the correct year, well before any partner opens their ITR12.
Share the IT3(BO) reference number with each partner so they know it's done.
Diarise to repeat every year, even when nothing has changed.