Case file ITA-2025-DIGITAL
Digital services supplied to an associate in Uganda taken out of the non-resident digital services tax and into withholding
Highest rung reached: Verified lawLaw: read in a statutory textRate structure · Revenue
1 point pending verification
- The FY2025/26 budget speech and any estimate.
Law
- Principal Act
- Income Tax Act (Cap 338), enacted as Act 11 of 1997
- Amending Act
- Income Tax (Amendment) Act 2025 (Act 13 of 2025) (verified)
- Provision, revised numbering (2023 revision)
- s. 86(5) and (6)
- Provision, numbering before the revision
- not stated in any source read
- Principal Act dates
- commencement 1997-07-01
- Amending Act in force from
- 1 July 2025 (assented 30 June 2025; gazetted 4 July 2025)
- Tax heads and taxpayers affected
- Income tax, Withholding tax. Non-resident groups supplying digital services to their Ugandan affiliates.
- Status
- Legal: in force. Implementation: pending verification.
| Section A: The law | |
|---|---|
| Amending Act | Income Tax (Amendment) Act 2025 (Act 13 of 2025) |
| In force from | 1 July 2025 |
| Assent | 30 June 2025 |
| Section B: What the law said before | |
| Nothing: this provision is new. Section 86 had subsections (1) to (4) only; digital services to an associate were taxed at 5% under section 86 like any other customer.Checked in ULII-ITA-2024, PDF page 57, s. 86 | |
| *** END OF CHANGE SLIP *** | |
The wording in force
as at 2025-07-01
(5) This section shall not apply where a non-resident person is deriving income from providing digital services in Uganda to an associate in Uganda. (6) Notwithstanding subsection (5), section 82 or 84 shall apply to the income of a non-resident person derived from providing digital services in Uganda to an associate in Uganda. Verified law: Wording or a date read in a statutory text, with the version and page named.[ACT-ITA-2025-13, PDF page 4, s. 4]
Redline pending verification
Reason
Stated objective pending verification
Revenue
Amendment-level revenue contribution not reliably quantified.
- 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.Missing. No official forecast for this measure was found in the budget documents or URA reports read. The budget speech and the Finance Bill memorandum for the year would settle it (MoFPED).
- Rung 3
Reported yield
Reported yield: What URA attributes to a measure after the year. An official attribution, not a causal estimate.Missing. URA's annual revenue reports read for the register attribute no yield to this measure. URA's measure-level policy tables, where they exist, would settle it (URA Research and Planning).
- 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.Missing. No source read for the register describes effects on prices, compliance cost, investment or equity.
What is known, what is uncertain, and what would settle it
- Known: only the collections of the tax heads affected.
- Uncertain: official forecast, reported yield, static or modelled estimate, causal estimate, wider impact; and 1 open point below.
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 change in how the rate is set, not only its level.
- implementation: no evidence. No source read dates its implementation.
- response: no evidence. No source read describes how taxpayers responded.
- outcome: no evidence. No reported yield or estimate.
- wider: no evidence. No source read measures wider effects. No evidence found is not evidence of no effect.
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
No criterion graded effective on the evidence read.
What did not
No criterion graded ineffective or counterproductive on the evidence read.
Open or not evaluated
Revenue effectiveness
The measure was not meant to raise revenue, or its direction is unknown.(graded by rule)
Not evaluated
Legal clarity and certainty
No source read for the register speaks to this criterion.
Not evaluated
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
Implementation quality
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
Afterlife
Linked records
- This record amends Income tax of 5% on non-residents supplying digital services to customers in Uganda. The 2025 Act amends section 86 of Cap. 338, which the register takes to be the 2023 Act's section 86A after the 2023 revision renumbered the Act; the renumbering table was not read. (pending)[ACT-ITA-2025-13, PDF page 4]
No Tax Appeals Tribunal or court decision on this provision is on record yet. That is not evidence that none exists.
Pending verification
- The FY2025/26 budget speech and any estimate.
Sources
ACT-ITA-2025-13
Income Tax (Amendment) Act, 2025 (Act 13 of 2025)
Parliament of Uganda; Uganda Printing and Publishing Corporation. 2025-07-04. Covers In force from its commencement.
Desktop/Tax legislation Amendment Acts/Income Tax (Amendment) Act, 2025.pdf
Status: verified. Pages confirmed for this record in the source audit: 4 (PDF).
Acts Supplement No. 9 to the Uganda Gazette No. 54, Volume CXVIII, dated 4 July 2025. Read in full (4 pages).