Tribunal Backs URA in UGX 10.2 Billion Century Bottling Tax Fight The Tax Appeals Tribunal has let URA pursue Century Bottling’s UGX 10.2b tax dispute for 2013–2019, rejecting claims the assessments were time-barred or “parallel.” The Tribunal said new audit facts reopened old years and upheld reverse-charge VAT on separately invoiced Krones services. Other issues on recharges and losses await ruling.

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 generally limited to three years, and Century Bottling Company said the clock had run out.

If the Tribunal agreed, everything else, value-added tax (VAT), income tax, and losses, would collapse with it.

Century Bottling Company also insisted URA’s later assessments overlapped earlier ones, calling them unlawful “parallel” assessments.

URA countered with a different storyline. It said the three-year rule doesn’t apply where an audit reveals new, material information.

During the prolonged review, URA argued it uncovered details about Century Bottling Company’s dealings that were not previously in its possession, especially around payments linked to Krones AG machinery support and other cost items. Those discoveries, URA said, legally reopened the years.

That procedural fight became the Tribunal’s first and biggest turning point.

In its 20 November 2025 ruling, the Tax Appeals Tribunal sided with URA, noting that the audit process had produced new information significant enough to trigger the legal exception allowing late assessments.

The effect was immediate and decisive: Century Bottling Company’s time-bar defence had collapsed, and URA was cleared to pursue the contested years.

Century Bottling Company’s second procedural complaint fell the same way. The Tribunal reviewed the assessment trail and accepted URA’s explanation that the later assessments were not duplicates but were based on fresh findings from the second audit.

In other words, URA was not recycling claims; it was expanding them on the back of new evidence.

With the gateway issues settled, the Tribunal moved to the headline substantive dispute already ripe for decision: VAT on Krones services.

Century Bottling Company had imported bottling and packaging equipment from Germany’s Krones AG.

Alongside the machines came commissioning, installation, calibration, testing, and technical training.

Century Bottling Company argued these services were merely incidental to the imported goods and should be treated as part of the customs value, meaning they shouldn’t attract separate VAT.

The Tribunal didn’t buy it. It drew a clear line between goods and services. Because the Krones services were contracted and invoiced separately, performed after importation, and not included in the customs value of the machinery, they were treated as imported services.

Under Uganda’s reverse-charge VAT rules, that made them taxable. The Tribunal therefore upheld URA’s VAT assessment on the Krones services—roughly UGX 364 million.

By the time the ruling reached that point, the direction of the case had shifted. Century Bottling Company had hoped to slam the door shut on timing and strip out the VAT head.

Instead, the Tribunal opened the door wider for URA, affirmed the legality of its assessment process, and confirmed that the Krones technical work attracted VAT.

The remaining battles, over the deductibility of “computer recharges” and the treatment of carried-forward losses, were left for further determination.

But the message of the ruling was already strong: when new information emerges in an audit, URA can lawfully go back beyond three years, and “incidental” services won’t escape VAT if they are separately priced and supplied.

For Century Bottling Company, it meant the fight was far from over, but it would now be fought from behind.