Case file EDA-2018-MMLEVY
Levy on mobile money withdrawals, cut from 1% to 0.5% of the value
Highest rung reached: Reported yieldLaw: read in a statutory textNew tax · Widen the base
1 point pending verification
- The text of the Act that cut the rate to 0.5% and limited it to withdrawals (listed as Act 12 of 2018), and its dates.
Law
- Principal Act
- Excise Duty Act (Cap 336), enacted as Act 11 of 2014
- Amending Act
- Amending Act listed as Act 12 of 2018 (Act 12 of 2018) (probable: the only amending Act in force from the right date, not confirmed)
- Provision, revised numbering (2023 revision)
- Sch. 2, item 13(e)
- Provision, numbering before the revision
- not stated in any source read
- Principal Act dates
- assent 2014-10-19; gazette 2014-10-24; commencement 2014-07-01; Uganda Gazette 61
- Amending Act in force from
- assent, gazettement and commencement dates pending
- Tax heads and taxpayers affected
- Excise duty. Mobile money users who withdraw cash.
- Status
- Legal: in force. Implementation: implemented.
| Section A: The law | |
|---|---|
| Amending Act | Amending Act listed as Act 12 of 2018 (Act 12 of 2018) |
| In force from | pending |
| Assent | pending |
| Section B: What the law said before | |
| The wording before and after is set out in the redline below. | |
| *** END OF CHANGE SLIP *** | |
The redline
as at 2018-07-01
Deleted: Mobile money transactions of receiving, payments and withdrawals: 1% of the value of the transaction;[ACT-EDA-2018-9, PDF page 7, s. 6(g)]
as at 2025-07-01
Inserted: Mobile money transactions of withdrawals of cash: 0.5% of the value of transactionVerified law: Wording or a date read in a statutory text, with the version and page named.[ULII-EDA-2025, printed page 14, PDF page 16, Schedule 2, item 13(e)]
Struck: the 1% levy as enacted by Act 9 of 2018 on receiving, payments and withdrawals. Underlined: the current Act. The Act that cut the rate, listed as Act 12 of 2018, was not read.
In plain English
Interpretation: A reading of the evidence, by a named source or by this register. Cash withdrawals from mobile money accounts carry a levy on the amount withdrawn, on top of the excise on the fee. The first version taxed transactions more broadly and was narrowed within the year.
Reason
Widen the tax base
Interpretation: A reading of the evidence, by a named source or by this register. [MOF-CG-1819, printed page 7, PDF page 10]
Marked as interpretation: the source states this objective, but either does not tie it to this measure in so many words or is not the Ministry that proposed it.
Policy objective as classified by the register: Widen the base. Intended revenue direction: raise.
Revenue
- Rung 1
Observed change
Observed: A value or event as an official source records it, copied without calculation.- Collections for the tax heads affected are drawn on the story page, from URA's annual data books. Before and after is never presented as this amendment's effect.
- Rung 2
Official forecast
Official forecast: What MoFPED or URA said a measure would raise, or why it was made, before the year began.- MoFPED: UGX 115 bn expected in FY2018/19 (Levy on mobile money).[MOF-CG-1819, printed page 8, PDF page 11]
- URA: UGX 115 bn expected in FY2018/19 (Levy on mobile money).[URA-ARR-1819, printed page 18, PDF page 24, Figure 15]
- Rung 3
Reported yield
Reported yield: What URA attributes to a measure after the year. An official attribution, not a causal estimate.- URA reports UGX 157.23 bn for FY2018/19, 136.72 percent of the forecast (computed).[URA-ARR-1819, printed page 18, PDF page 24, Figure 15]
- Rung 4
Static or modelled estimate
Modelled estimate: A mechanical or model calculation, with every assumption shown.Missing. No estimate made. A static estimate needs the taxable base before the change (volumes or values by product), which the register does not hold.
- Rung 5
Causal estimate
Causal estimate: An effect identified by a stated research design against a comparison group.Missing. No study with a defensible identification strategy was found for this amendment.
- Rung 6
Wider impact
Interpretation: A reading of the evidence, by a named source or by this register.- URA records that the 1% levy on transactions was revised to 0.5% on withdrawals as a result of the public outcry, and recommends research on policy implications before a pronouncement.[URA-ARR-1819, printed page 32, PDF page 38]
What is known, what is uncertain, and what would settle it
- Known: official forecast, reported yield, wider impact.
- Uncertain: static or modelled estimate, causal estimate; and 1 open point below.
- Would settle it: Request to the Clerk to Parliament for certified copies of the Excise Duty, Income Tax, Value Added Tax, Stamp Duty and Tax Procedures Code (Amendment) Acts of 2015 to 2025, with their dates of assent and Gazette notice numbers. Held by Uganda Printing and Publishing Corporation (Uganda Gazette); Parliament of Uganda Library; ULII.
Pathway
From the amendment to its wider consequences. Select a link to read what supports it. No money is drawn along the chain, because no flow along it is measured.
Verified: A source read for the register documents this link.
The provision is read in the ULII consolidated text.
- amendment: verified. The provision is read in the ULII consolidated text.
- mechanism: verified. A new charge on a base not taxed before.
- implementation: verified. URA reports performance for the measure, so it was applied.
- response: verified. URA records public outcry that led to the rate and base being changed.
- outcome: verified. URA reports a yield. It is an official attribution, not a causal estimate.
- wider: hypothesised. A shift back to cash for small payments is a plausible response; no source read measures it.
Consequences
Graded against ten criteria. No composite score: a reform that raises money can still be regressive or costly to comply with, and one that loses revenue can serve a legitimate aim. Revenue effectiveness is graded by a stated rule; the rest only where a source speaks to them.
What worked
Revenue effectiveness
Reported yield over MoFPED's forecast for FY2018/19: 136.7 percent.(graded by rule)
Effective
Implementation quality
The levy was collected from the first year, but URA records that it was revised from 1% on transactions to 0.5% on withdrawals after public outcry.[URA-ARR-1819, printed page 32, PDF page 38]
Partially effective
What did not
No criterion graded ineffective or counterproductive on the evidence read.
Open or not evaluated
Legal clarity and certainty
The rate and base changed soon after enactment, and the MoFPED guide and URA disagree on the order of events. The final text is clear; the transition is not documented here.[MOF-CG-1819, printed page 8, PDF page 11]
Inconclusive
Administrative feasibility
No source read for the register speaks to this criterion.
Not evaluated
Compliance cost
No source read for the register speaks to this criterion.
Not evaluated
Efficiency
No source read for the register speaks to this criterion.
Not evaluated
Investment and competitiveness
No source read for the register speaks to this criterion.
Not evaluated
Vertical and horizontal equity
No source read for the register speaks to this criterion.
Not evaluated
Distributional effect
No source read for the register speaks to this criterion.
Not evaluated
Unintended consequences
No source read for the register speaks to this criterion.
Not evaluated
Consequences on record
- Interpretation: A reading of the evidence, by a named source or by this register.URA records that the 1% levy on transactions was revised to 0.5% on withdrawals as a result of the public outcry, and recommends research on policy implications before a pronouncement.[URA-ARR-1819, printed page 32, PDF page 38]
Afterlife
Later changes, cases and practice
- Unverified: Not yet checked against a primary source. Shown so the gap is visible.The Citizen's Guide dated June 2018 already describes the levy as 0.5%, while URA describes a 1% levy later revised. The order of events is pending verification.[MOF-CG-1819, printed page 8, PDF page 11]
- Observed: A value or event as an official source records it, copied without calculation.URA first told operators on 29 June 2018 that the 1% duty on 'receiving' covered cash deposits and bank-to-wallet transfers, withdrew that reading on 4 July 2018, and on 24 July 2018 directed that customers taxed from 1 to 4 July be refunded. A challenge in the High Court was dismissed as overtaken by events; the court held it had jurisdiction, as a claim to enforce the right to property, not a tax dispute.[ULII-UGHCCD-2019-5, Ruling, background and the issue whether the case is overtaken by events]
Before the Tribunal and the courts
Turyakira and Another v Uganda Revenue Authority Miscellaneous Cause No. 166 of 2018, [2019] UGHCCD 5
High Court, Civil Division, 8 February 2019
Dismissed as overtaken by events, each party bearing its own costs. The court held that it had jurisdiction, since the claim was to enforce the right to property under Article 50 and not a tax dispute for the Tribunal, but URA had withdrawn its reading that deposits were taxable on 4 July 2018, before the case was filed, and had ordered refunds.
Pending verification
- The text of the Act that cut the rate to 0.5% and limited it to withdrawals (listed as Act 12 of 2018), and its dates.
Sources
MOF-CG-1819
Know Your Budget 2018: A Citizen's Guide to the Budget of FY 2018/19
Ministry of Finance, Planning and Economic Development. 2018-06. Covers FY2018/19.
Status: verified. Pages confirmed for this record in the source audit: 10, 11 (PDF).
Fetched online and read page images of PDF pages 10 and 11 (printed pages 7 and 8). It summarises the budget speech; the speech itself was not read.
URA-ARR-1819
Annual Revenue Report FY 2018/19
Uganda Revenue Authority. 2019. Covers FY2018/19.
Desktop/Personal/URA DATA BOOKS AND REVENUE REPORTS/Annual Revenue Report FY 2018-19.pdf
Status: verified. Pages confirmed for this record in the source audit: 24, 38 (PDF).
Figure 15 (PDF page 24, printed 18), Table 10 (PDF page 37, printed 31) and Table 11 (PDF page 38, printed 32) read from page images. The measure-level annex (A3) is an embedded Word file that is not in the PDF.
URA-ARR-1920
Annual Revenue Report FY 2019/20
Uganda Revenue Authority. 2020. Covers FY2019/20.
Desktop/Personal/URA DATA BOOKS AND REVENUE REPORTS/Annual Revenve Report FY 2019-20.pdf
Status: verified. No page of this source is confirmed for this record by the audit; it is cited for context.
Table 20 (PDF page 50, printed 43) and Annex 3, the measure-level table (PDF pages 60 to 62, printed 53 to 55), read from page images. The file name misspells Revenue.
URA-ARR-2021
Annual Revenue Report FY 2020/21
Uganda Revenue Authority. 2021. Covers FY2020/21.
Desktop/Personal/URA DATA BOOKS AND REVENUE REPORTS/Annual Revenue Report FY 2020-21.pdf
Status: verified. No page of this source is confirmed for this record by the audit; it is cited for context.
Table 21 (PDF page 42, printed 36) and Figure 7 (PDF page 19, printed 13) read from page images.
REPO-REVENUE
Revenue collections and targets by tax head (data/raw/Revenue_by_TaxHead.json)
Uganda Revenue Authority, Annual Data Books FY2019/20 and FY2024/25, as compiled in this repository. 2026. Covers FY2015/16 to FY2024/25.
data/raw/Revenue_by_TaxHead.json
Status: verified. No page of this source is confirmed for this record by the audit; it is cited for context.
Existing repository extract, reused, not copied.
ULII-EDA-2025
Excise Duty Act (Chapter 336), version of 1 July 2025
Uganda Legal Information Institute (ULII) and Laws.Africa, from the Law Reform Commission revision. 2025-07-01. Covers Text in force from 1 July 2025; revised and consolidated as at 31 December 2023, later amendments applied by Laws.Africa.
Desktop/Personal/Tax Legislation and URA Returns/Excise Duty Act Cap 336.pdf
Status: verified. Pages confirmed for this record in the source audit: 16 (PDF).
Read in full with pdftotext. Lists amending Acts on PDF page 3.
ULII-UGHCCD-2019-5
Turyakira John Robert and Odur Anthony v Uganda Revenue Authority, Miscellaneous Cause No. 166 of 2018, [2019] UGHCCD 5 (ruling of 8 February 2019)
High Court of Uganda, Civil Division (Ssekaana J), as published by ULII. 2019-02-08. Covers Ruling.
https://ulii.org/en/akn/ug/judgment/ughccd/2019/5/eng@2019-02-08
Status: verified. No page of this source is confirmed for this record by the audit; it is cited for context.
Read in full from the Word copy published by ULII. The ruling has no page numbers; citations give the part of the ruling.
ACT-EDA-2018-9
Excise Duty (Amendment) Act, 2018 (Act 9 of 2018)
Parliament of Uganda, published by the Uganda Printing and Publishing Corporation. 2018-06-29. Covers Assented 21 June 2018; in force 1 July 2018.
Desktop/Tax legislation Amendment Acts/Excise Duty (Amendment) Act, 2018.pdf
Status: verified. Pages confirmed for this record in the source audit: 7 (PDF).
Acts Supplement No. 2 to the Uganda Gazette No. 33, Volume CXI, dated 29 June 2018. Read in full from the text layer of the copy supplied by the author (9 pages).
Corrections to this record
- 2026-10-20 Stated reason reclassified from OFFICIAL FORECAST to INTERPRETATION. The Citizen's Guide (printed page 7) lists nine objectives for the year's measures without tying each objective to a measure. Matching this objective to this measure is the register's reading, not the Ministry's statement. Previously: OFFICIAL_FORECAST.
- 2026-10-21 Turyakira and Another v URA [2019] UGHCCD 5 read in full; the case marked read and the record's afterlife extended with URA's directives of 29 June, 4 July and 24 July 2018. The ruling sets out the order of URA's directives on cash deposits, which the register had not documented.
- 2026-10-21 Redline now strikes the 1% levy in the words of Act 9 of 2018 instead of URA's description. The enacted wording is now available.