A Trust has trustees, who manage the trust for the benefit of it’s beneficiaries.
It is not a difficult process to change the trustees or beneficiaries on a trust, and any changes would not pass through the city of Johannesburg.
When a trust is opened, the assets in the trust therefore belong to the trust - Not to any particular person. Therefore it is not possible to say that the trust is a pensioner.
It may be argued that the trustees and beneficiaries of the trust are all of pension age, however due to the fact that trustees and beneficiaries may be changed at any time, there is no possible means for City of Jhb to ensure that the trust remains in the control of pensioners.
Therefore, rates rebates are offered only to individuals and not to any entity (Trust, Close Corporation or Company)