The Tax Appeals Tribunal has upheld a $100,000 (UGX357 million) penalty imposed on TotalEnergies EP by Uganda Revenue Authority (URA) for failing to provide transfer pricing information within prescribed timelines during a tax audit. The ruling reinforces URA’s enforcement powers over multinational companies operating in Uganda. In a decision delivered to end almost two years of a legal battle, the Tribunal ruled that URA acted lawfully in penalising the oil and gas company under the Income Tax Act, after finding that key documents requested during a transfer pricing audit remained outstanding for several months despite repeated notices and deadline extensions….
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Century Bottling Company Limited walked into the Tax Appeals Tribunal hoping to end a costly dispute before it truly began. The Coca-Cola bottler was facing a fresh set of tax assessments from Uganda Revenue Authority (URA) covering 2013–2019, claims that pushed the disputed bill to roughly UGX 10.2 billion. To Century Bottling Company, the audit felt like a second bite at the same apple. To URA, it was a necessary correction after uncovering new facts. Century Bottling Company’s strategy was built around a procedural knockout. The company argued that URA had come too late. Under tax law, additional assessments are…
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Uganda’s High Court has issued a decision that reshapes the rules of engagement in tax disputes. The decision gives clarity on the much-contested 30% deposit requirement and reins in the contempt powers of the Tax Appeals Tribunal (TAT). The case arose when Nile Breweries disputed additional tax assessments issued by the Uganda Revenue Authority (URA) for VAT and excise duty. Nile Breweries had already paid its self-assessed taxes but challenged URA’s additional demand, which it viewed as unlawful. While seeking an injunction before the Tax Appeals Tribunal, a condition was imposed that Nile Breweries pays 30% of the tax “in…
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In April 2024, Ms. Crystal Kabajwara made history as the first female Chairperson of Uganda’s Tax Appeals Tribunal (TAT). Her appointment marked a defining moment for the institution, which has…
Congratulations on completing your first year as Chairperson of the Tax Appeals Tribunal. For starters, many people do not understand the mandate of the Tribunal as well as, how does…
The Tax Appeals Tribunal has ordered the Uganda Revenue Authority (URA) to refund over USD 2.5 million (UGX 9.1 billion) to East Africa Marine Transport Company Limited (EAMT). The ruling, delivered on April 30, 2025, centered on a disputed Value Added Tax (VAT) charged on the purchase of M.V. Mpungu, the first scheduled roll-on/roll-off freight vessel operating on Lake Victoria. The tribunal found that URA had wrongly levied VAT on the vessel, despite EAMT’s investment being eligible for VAT exemption under Uganda’s laws encouraging strategic sector development. EAMT, a logistics and marine transport company, had committed to invest at least…
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The Tax Appeals Tribunal, sitting in Kampala has set aside a UGX4.6 billion import duty assessment against paint makers, Kansai Plascon Uganda. The company dragged the Uganda Revenue Authority (URA) to the Tribunal, challenging an import duty assessment of UGX4,623,958,639 on raw materials imported between 2017 to 2021 from Egypt, namely long oil alkyd resins, polymers and calcium carbonate. Egypt, just like Uganda, is a member of the Common Market for Eastern and Southern Africa (COMESA); therefore, the said goods were supposed to enjoy preferential tax status. In the tax dispute, URA told the court that during this period, Kansai…
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The Tax Appeals Tribunal (TAT) has disallowed a UGX 504,098,312 tax bill by Uganda Revenue Authority (URA) on asset-financing firm Tugende Limited, saying the tax authority wrongly assessed the tax. The 2 against 1 majority ruling follows an application by Tugende Limited arguing that the tax assessment was based on discounts to its customers who repaid their leases early, yet these should be allowable expenses. URA disagreed and issued an additional income tax assessment of UGX504,098,312 which the applicant objected to. Tugende was represented by Oscar Kamusiime and Linda Mugisha from Birungyi, Barata & Associates, while URA was represented by…
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Birungyi Cephas Kagyenda of Birungyi, Barata & Associates (BBA) is probably Uganda’s foremost tax professional with rich legal knowledge spanning 36 years in Taxation, Commercial and Corporate Law, Energy and Construction; Dispute Resolution, Insolvency and Employment as well as Advisory and Consultancy. He has worked for the Ministry of Finance from 1984 and later Uganda Revenue Authority where he retired as a Deputy Commissioner in 2004 after cofounding BBA in 2003. He is now the Managing Partner at the firm. BBA itself is one of the leading tax law firms in Uganda that handles up to 35% of all tax…
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A tax informer’s right to claim for a reward accrues at the time the information is provided but not at the time of the recovery of tax, Tax Appeals Tribunal (TAT) has ruled. While citing Section 8 of the Finance Act, the Tax Tribunal affirmed that an informer’s right to a reward is created immediately upon the provision of tax liability information by the whistle blower. “…The right of an informer reward is a proprietary right, it is intangible property. The right accrues as soon information is given to the respondent (Uganda Revenue Authority- URA) and forms when the tax…
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