Kampala Associated Advocates (KAA) has been tapped to represent Stanbic Bank Uganda and its parent, Stanbic Uganda Holdings Limited, in one of the largest transfer-pricing disputes to reach the Tax Appeals Tribunal (TAT) in recent years — a case carrying a working exposure figure of roughly UGX 117.8 billion.
The case, filed by KAA in June 2025 under TAT Application No. 170 of 2025, challenges an assessment by the Uganda Revenue Authority (URA) arising from years of intra-group charges, franchise fees, technology cost allocations and profit-sharing arrangements between Stanbic and its parent entities. At its core, the dispute tests how far multinationals can go in allocating shared costs across borders — and whether those structures meet Uganda’s transfer-pricing standards.
A dispute that could reset expectations
URA contends that elements of Stanbic’s related-party charges were either mispriced, duplicated or allocated in ways that reduced the Ugandan subsidiary’s taxable income. Stanbic counters that the charges were benchmarked to international arm’s-length principles and reflect legitimate cost-sharing across a modern, group-wide banking platform.
The bank has framed the issue as technical, procedural and interpretive — not a question of misconduct — leaving the Tribunal to determine how Uganda’s transfer-pricing rules apply to complex, cross-border financial operations.
A ruling in URA’s favour could tighten scrutiny on multinationals, influence dividend planning, and force companies to overhaul documentation practices. A Stanbic victory, meanwhile, would clarify boundaries around documentation timing, duplication claims and technology cost allocation — lessons likely to echo across boardrooms.
Why KAA matters in this battle
KAA is widely regarded as one of Uganda’s most experienced tax litigation and dispute-management firms, routinely handling multi-billion-shilling conflicts involving utilities, telecoms, oil and gas companies, banks and parastatals. The firm has successfully navigated capital-gains controversies, VAT battles, customs re-classification disputes and complex income-tax assessments — often in cases that ultimately set precedent for future enforcement.
Its lawyers have appeared before the Tax Appeals Tribunal, Commercial Court and Court of Appeal, and have also negotiated settlements where litigation threatened to drag on, preserving both financial and reputational value for clients. Over the years, KAA has acted on headline disputes involving Tullow Oil, UMEME, Standard Chartered Bank, NSSF and other blue-chip institutions — repeatedly being called in when tax disagreements escalated into legal flashpoints.
The likely architects: Oscar Kambona and Bruce Musinguzi
By publication time, KAA had not confirmed the exact composition of its Stanbic legal team. However, given the size and complexity of the matter, industry observers expect the case to be led by the firm’s senior tax strategists — Senior Partner Oscar Kambona and Partner Bruce Musinguzi.
Oscar Kambona — The strategist with deep institutional memory
Kambona is one of Uganda’s best-known tax litigators. A former legal adviser to the URA Commissioner General and consultant to the Tax Appeals Tribunal, he combines courtroom acumen with an insider’s understanding of how tax policy is interpreted and enforced. He has worked on some of the largest disputes ever tested in Uganda — notably capital-gains tax cases arising from oil-sector transactions, high-value VAT appeals and income-tax disputes cutting across telecoms, energy and infrastructure.
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His experience advising government, parastatals and multinationals alike gives him a rare ability to read the motivations on both sides of a tax fight — an asset in a complex transfer-pricing case where legal nuance and negotiation strategy matter as much as the technical calculations themselves.
Bruce Musinguzi — Transfer-pricing tactician with global exposure
Co-heading the tax practice, Musinguzi brings an LLM in International Tax from Georgetown University, bolstered by professional experience with PwC USA and JP Morgan. Over more than a decade, he has led litigation and advisory mandates involving corporate tax, VAT, customs, and — critically — transfer-pricing and cross-border cost allocation.
He has represented multinationals in disputes worth hundreds of billions of shillings, guided banks through high-stakes tax audits, and advised corporates facing questions over technology platforms, management fees and intra-group services — precisely the themes now contested in the Stanbic case.
Together, Kambona and Musinguzi have built a reputation for balancing technical rigor with pragmatic dispute resolution, steering matters from audit stage through TAT and into appellate courts when necessary.
A wider signal to the market
Stanbic’s case comes at a time when tax enforcement in Uganda is tightening. The Uganda Revenue Authority has stepped up its scrutiny of multinational business structures, paying closer attention to how subsidiaries share costs with their parent companies. Increasingly, URA is testing whether local entities are paying only for benefits they can clearly demonstrate, whether technology and platform costs are being allocated in a fair and justifiable way across the group, and whether any charges are duplicated in ways that result in the same service being billed twice.
Against that backdrop, the Stanbic dispute is likely to become a reference point for future audits — influencing how companies prepare and defend their pricing documentation, and how assertively URA applies its interpretation of the arm’s-length principle going forward.
What happens next
The matter now proceeds before the Tax Appeals Tribunal, with arguments expected to centre on pricing methodology, allocation logic, comparables, documentation timing and statutory limitation periods. An appeal — whichever side loses — appears likely.
For Kampala Associated Advocates, the mandate reinforces its status as a go-to firm when the financial and policy stakes escalate.
