The Nile Breweries-URA UGX 18.5 Billion Fight: When ‘Export’ Became the Battleground That NBL Eventually Lost A beer export model just cost Nile Breweries about UGX 18.5b. The Tax Appeals Tribunal ruled that ‘export agents’ Kabaco and Ituri were in fact local buyers, not agents, so their cross-border sales didn’t qualify as NBL exports. Labels aside, risk and title passing in Uganda proved legally decisive.

On paper, it looked like a clean regional trade story: a Ugandan manufacturer producing beer for thirsty markets in South Sudan and DR Congo, using local distributors to move product across borders. In reality, it became a high-stakes tax dispute that turned on a single question: who, legally, exported the beer? The business model behind the case was straightforward. Nile Breweries Limited (NBL) has long exported into the region. In 2022, it supplied beer to Kabaco and Ituri, two Uganda-based companies with established export networks outside the country. The beer was clearly marked “for export,” and the arrangement was framed…