Inside the UGX117.8 Billion Stanbic vs URA Transfer Pricing Tax Dispute What began as a routine tax review has turned into a UGX117.8 billion showdown — one with the potential to ripple through boardrooms, unsettle shareholders and reshape how multinationals operate in Uganda. And while it centres on Stanbic, this is no isolated case: it is part of a growing wave of transfer-pricing disputes as URA steps up scrutiny of how global groups allocate costs, book profits and move value across borders.

Stanbic Bank Uganda and its parent holding company, Stanbic Uganda Holdings Limited (SUHL), are battling a sweeping transfer-pricing assessment by the Uganda Revenue Authority (URA), now before the Tax Appeals Tribunal under TAT Application No. 170 of 2025 — the latest in a growing wave of transfer-pricing disputes, as URA intensifies audits on multinationals — a campaign that has swept through most large foreign-owned firms in recent years. At the core of the Stanbic-URA tax dispute lies a critical question: Did Stanbic Bank’s and SUHL’s related-party charges reflect true market value — or did the bank understate taxes through mispriced…