According to the Donations Tax page on SARS website under the heading:”what steps must I take”
SARS advises as follows: After making a donation you should fill in form IT 144 and send it to SARS with your payment”.
Whether this implies that you must submit form IT 144 when there is no payment to be made is a moot point. However ,as a taxpayer may make several donations during a year of assessment ,it may be advisable to submit IT 144 declarations even if there is no donations to be paid at various times during the relevant year of assessment. Reason been that should cumulative donations exceed R100000.00 at any given time in that year ,the tax can be calculated and paid timeously to avoid interest and penalties.
I notice that Silke on South African Income Tax(electronic Version) at paragraph 23.18 writes as follows: : SARS requires a declaration(IT 144) by the donor for every donation ,whether or not it is exempt from tax”.
Incidentally the Tax Administration Act (Act 28 of 2011)under section 1 defines a return as follows:
“Return means: a form,declaration...or other manner of submitting information to SARS... required under section25 ,26 of 27 or a provision under a tax act...”
Hope this helps and is not too long winded.