By CEO East Africa Magazine Team
Uganda’s ambition is bold: to grow its economy tenfold, moving millions out of poverty and cementing its place among Africa’s rising stars. The 2025/26 national budget, with a resource envelope of UGX 72.4 trillion, sets the tone — prioritising human capital, infrastructure, industrialisation, and digital transformation. But behind the optimism lies a fiscal squeeze. Public debt is climbing past USD 31.5 billion (51.26% of GDP), leaving little room for fresh borrowing.
That means financing Uganda’s 10x dream depends squarely on domestic revenue mobilisation. Rather than introducing new taxes, the government is tightening administration — plugging leaks, formalising informal sectors, and enforcing compliance through tools like the Electronic Fiscal Receipting and Invoicing System (EFRIS).
For taxpayers, the effect is palpable: not higher tax rates, but higher scrutiny and compliance costs. The result? An unprecedented rush to the Tax Appeals Tribunal (TAT) as businesses, NGOs, banks, and even schools challenge URA assessments.
The government has committed to raising UGX 37.2 trillion in domestic revenue, of which UGX 34 trillion is tax revenue.
The expansion of EFRIS in July 2025 now requires even small and informal operators — from transporters to food vendors — to issue digital receipts for every transaction. While designed to curb evasion and widen the tax base, the compliance burden has left many struggling to adapt, risking exclusion from supply chains or stiff penalties.
This “tightening without taxing” has triggered widespread contestation. Businesses argue that the cost of compliance is tantamount to a hidden tax. URA, under pressure to deliver revenue, is ramping up assessments and penalties. Inevitably, disputes are flooding the Tribunal.
A Nation in Tax Dispute
Uganda’s tax system today resembles a pressure cooker. The Tax Appeals Tribunal’s FY25 performance report reveals a surge of litigation unmatched in its 26-year history. In just twelve months, 410 new disputes worth UGX 656 billion were filed, pushing the Tribunal’s caseload to 429 pending disputes valued at UGX 1.2 trillion by June 2025. Even after disposing of 266 cases worth UGX 506 billion — more than double the previous year — the Tribunal ended the year with more disputes on its books than ever before.
The judgment outcomes for matters that went to trial reveal much about Uganda’s tax landscape- URA won 56% of cases by number, representing 73% of the disputed tax, while Taxpayers won 44%, but only 27% of the tax value. In cases that were mediated by TAT to reconcile taxpayers’ liabilities, the URA, on average, vacated 70% of the assessments.
A look at the September 2025 cause list illustrates the strain. In a single week, the Tribunal is juggling over 80 matters, with daily sittings packed from 9:00 AM to 2:30 PM and up to 18 cases per day. The docket is crowded with a mix of hearings, mentions, rulings, and conferencing sessions, underscoring how both substantive disputes and procedural delays are piling pressure on the system. Hearings involve full arguments on contested assessments, such as Techno Three Uganda Ltd v URA, Eco Bank Uganda Ltd v URA, and DFCU Ltd v URA. Mentions — the most numerous — show the Tribunal’s role in case management and adjournments, while rulings in big-ticket cases like Quality Chemical Industries Ltd v URA, Farm Inputs Care Centre (FICA) Ltd v URA, and Visare Uganda Ltd v URA highlight its responsibility for shaping precedent.
The range of litigants shows how far the squeeze has spread. Large corporates and financial institutions dominate, including Eco Bank, DFCU, Housing Finance, Yako Bank, Cairo Bank, Uganda Breweries, Crown Beverages, Quality Chemicals, and even Uganda Railways. Alongside them are SMEs and traders such as Kitandwe Enterprises, Kulika Uganda, SHP Sons, Jazz Supermarket, and Nabbira Nalubega Property Services, whose cases often hinge on survival. Civil society organisations and NGOs — including SIHA (Strategic Initiative for Women in the Horn of Africa) and the Auschwitz Institute for Peace & Reconciliation — are battling over tax treatment of non-profit work, echoing earlier humanitarian disputes like Pentecostal Assemblies of God v URA. Even schools and faith-based institutions, such as Mt. St. Henry School Mukono and Ebenezer Nursery/Primary School, are resisting URA assessments that threaten to raise costs for parents and communities.
Patterns are emerging from this flood of litigation. Banks and financial institutions are repeatedly challenging withholding tax, PAYE, and VAT on services. Manufacturers and traders, especially in food, beverages, and construction, are contesting excise duties, VAT on inputs, and eligibility for incentives. NGOs and relief agencies are fighting to protect humanitarian exemptions, while schools and religious bodies are testing whether they should be taxed like private businesses. Frequent requests for extensions of time signal that even with reforms, congestion and procedural delays persist.
All of this unfolds under the watch of a rotating bench of three-member panels, with most members appearing throughout the week, with most sitting almost daily — evidence of just how stretched the Tribunal’s leadership has become.
The key takeaway is stark: the Tribunal is under enormous pressure with a docket that is not only large and diverse but also increasingly high-stakes.
Tax exemptions and classifications — especially for NGOs, schools, telecommunications and relief goods — remain fiercely contested, while financial institutions and manufacturers carry the biggest monetary disputes.
The September cause list makes clear that Uganda is now a nation in tax dispute, with the Tribunal caught in the middle of an escalating cycle of new filings, ongoing battles, and precedent-setting rulings that reflect the growing tension between URA’s enforcement drive and taxpayers’ resistance.
TAT to the Rescue — But Also Under Strain
For Crystal Kabajwara, the Chairperson of the Tax Appeals Tribunal, the institution’s role has never been more pivotal. “The URA’s mandate is to collect as much as possible; taxpayers’ instinct is to pay as little as possible. The two will always be in conflict. That is where we come in — to build and restore trust in the tax system by providing an independent avenue for resolving disputes,” she told CEO East Africa Magazine in an earlier interview.
Netflix Strikes $82.7 Billion Deal to Take Over Warner Bros., Redefining the Global Entertainment LandscapeUnder her stewardship, the Tribunal has increasingly become a pressure valve for Uganda’s strained tax system, absorbing the friction between an ambitious state hungry for revenue and taxpayers desperate for relief.
Several reforms illustrate this shift— sessions have doubled, thanks to the operationalisation of a second courtroom, allowing the Tribunal to hear as many as 16 matters a day. Another reform — mandatory conferencing now requires taxpayers and URA officers to sit across the table before full hearings begin — cutting through paperwork delays and often narrowing disputes to their core issues. Mediation has also been mainstreamed, with nearly 70% of disputes now settled through reconciliation of figures and interpretations, reducing the need for protracted litigation.
These reforms have translated into results: in FY25, the Tribunal disposed of 266 disputes worth UGX 506 billion, releasing funds back into the economy that would otherwise have been tied up in tax assessments. For SMEs, the speed of these disposals can be the difference between survival and collapse. For large corporates, they provide certainty and clarity in navigating an increasingly complex tax landscape.
Yet even as it rescues taxpayers from the weight of unresolved disputes, the Tribunal is itself under pressure. Funding shortfalls have slowed investment in digital tools needed to automate filings and track cases. Staffing gaps in legal research and analysis strain the Tribunal’s capacity to keep pace with the complexity of disputes, many of which involve billions of shillings and novel interpretations of tax law. And the persistence of manual case management systems means that, despite reforms, hearings can still be bogged down by adjournments, incomplete records, or procedural delays.
The paradox is striking: while the Tribunal is resolving more cases than ever before, its caseload continues to outgrow its capacity. By June 2025, 429 disputes worth UGX 1.2 trillion remained pending. As Kabajwara herself has acknowledged, the Tribunal is racing to cut case turnaround times from 10 months to six — but without additional resources, automation, and public education, the backlog will remain a shadow over its achievements.
In effect, TAT has become both a lifeline and a bottleneck. It is the venue taxpayers now trust to level the playing field against URA, but it is also an institution feeling the same squeeze that defines the wider tax system: high expectations, limited resources, and rising pressure on all sides.
Balancing Growth and Trust
The paradox is stark. Uganda needs more revenue to finance its 10x dream, but overzealous enforcement risks stifling the very businesses meant to drive that growth.
As Kabajwara sees it, the Tribunal’s role is bigger than resolving disputes — it is about restoring faith in the tax system. With plans to launch an open day, expand regionally, and digitise processes, TAT is positioning itself as both arbiter and educator.
Still, as long as the revenue gap persists and URA doubles down on compliance, the Tribunal will remain crowded. Uganda’s growth story, for now, comes with a caveat: ambition at the front, disputes at the back, and a Tribunal stretched in between.
Experts See a Stronger, Faster, Fairer Tribunal — But Warn of Growing Strain
Among tax practitioners that the CEO East Africa Magazine spoke to, there is growing recognition that the Tax Appeals Tribunal has undergone a remarkable transformation. Many legal professionals who have interacted with it over the years describe a shift from a slow-moving administrative body into a focused, disciplined, and outcome-driven institution. Hearings are now said to be more purposeful, with schedules structured around resolving substantive issues rather than routine adjournments. The Tribunal’s ability to issue multiple rulings weekly — something previously unthinkable — is cited as evidence of a new culture of efficiency and accountability.
Reforms around conferencing and mediation have been particularly impactful. Lawyers observe that mediation has evolved from a procedural formality into a genuine mechanism for resolving disputes early and amicably. Nearly 70 per cent of cases are now settled through dialogue and reconciliation of figures before reaching full hearing, saving both time and costs. Practitioners note that mediators are holding both URA and taxpayers accountable, ensuring that resolutions are meaningful and durable. This has contributed significantly to reducing the backlog and improving the perception of fairness in tax administration.
Still, while there is broad praise for the Tribunal’s performance, there is also a common note of caution. The very success of these reforms has generated new pressures. As confidence in the Tribunal grows, more taxpayers are turning to it for redress, creating an ever-expanding caseload. Legal experts point to the need for greater financial and institutional support — particularly in staffing, digitalisation, and research capacity — to sustain the current momentum. Without that, they warn, the Tribunal risks being overwhelmed by its own success.
The consensus among practitioners is clear: the Tribunal has redefined how tax justice is administered in Uganda. It is faster, more transparent, and more trusted than ever before. Yet, its future effectiveness will depend on whether it receives the resources to match the rising demand for its services — and to keep justice moving in a system already stretched by the pressures of Uganda’s ambitious growth agenda.
Ambition at the Front, Disputes at the Back
Uganda’s 10x growth dream depends on mobilising more revenue without raising tax rates, a strategy that has tightened compliance and enforcement across the board. The result is a surge of disputes crowding the Tribunal’s corridors, with the September 2025 cause list alone listing more than 80 matters in a week. From banks and manufacturers to NGOs, schools, and small traders, taxpayers are increasingly turning to the Tribunal as the ultimate arbiter of fairness in a tax system under strain.
The Tribunal has risen to the challenge, doubling sessions, expanding mediation, and unlocking record sums back into circulation. In FY25 alone, UGX 506 billion was released from contested assessments — money that either flowed into the government purse to fund national priorities or returned to taxpayers as working capital to sustain and grow their businesses. Yet with 429 disputes worth UGX 1.2 trillion still pending, the Tribunal itself feels the squeeze. Whether Uganda’s 10x dream succeeds will hinge not only on URA’s collections but also on how quickly and fairly the Tribunal can release resources tied up in disputes, keeping both the state and its taxpayers liquid enough to drive growth.
