Case file ITA-2026-DEBENTURES5
Withholding tax of 5% on debenture interest paid by a resident company to non-residents
Highest rung reached: Verified lawLaw: read in a statutory textWithholding · Revenue
2 points pending verification
- A revenue estimate: the speech gives none.
- URA's yield for the measure: URA's reports print yields by tax head only from FY2022/23, so a figure for this measure alone may never be printed.
Law
- Principal Act
- Income Tax Act (Cap 338), enacted as Act 11 of 1997
- Amending Act
- Income Tax (Amendment) Act 2026 (Act 21 of 2026) (verified)
- Provision, revised numbering (2023 revision)
- s. 82(5); Sch. 4, Part V, para. 2A
- 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 2026 (assented 20 August 2026; gazetted 28 August 2026)
- Tax heads and taxpayers affected
- Withholding tax, Income tax. Resident companies borrowing abroad through debentures, and their foreign lenders.
- Status
- Legal: in force. Implementation: pending verification.
| Section A: The law | |
|---|---|
| Amending Act | Income Tax (Amendment) Act 2026 (Act 21 of 2026) |
| In force from | 1 July 2026 |
| Assent | 20 August 2026 |
| Note | Applied from 50 days before it became law. |
| Section B: What the law said before | |
Interest paid by a resident company in respect of debentures is exempt from tax under this Act where the following conditions are satisfiedBefore 1 July 2026 the interest was exempt when the debentures were issued outside Uganda to raise a loan outside Uganda, widely issued (or paid to a bank or public financial institution), and the interest paid outside Uganda. The 2026 Act replaces the exemption with a 5% rate.ULII-ITA-2024, PDF page 56, s. 82(5) | |
| Section C: What it does to a worked example | |
| Non-resident lender: UGX 100m qualifying debenture interest | 0 → 5,000,000 +5,000,000 UGX of taxVERIFIED LAW: exempt under s. 82(5) before; 5% after |
| Section D: Paperwork | |
| The paying company now withholds and files | |
| *** END OF CHANGE SLIP *** | |
The wording in force
as at 2026-07-01
2A. The withholding tax rate on the interest paid by a resident company in respect of debentures to a non-resident person under section 82 (5) is 5%. Verified law: Wording or a date read in a statutory text, with the version and page named.[ACT-ITA-2026-21, PDF page 10, s. 16(b)]
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 2 open points 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. Tax collected at source by the payer.
- 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
No Tax Appeals Tribunal or court decision on this provision is on record yet. That is not evidence that none exists.
Pending verification
- A revenue estimate: the speech gives none.
- URA's yield for the measure: URA's reports print yields by tax head only from FY2022/23, so a figure for this measure alone may never be printed.
Sources
MOF-BS-2627
Budget Speech, Financial Year 2026/27
Ministry of Finance, Planning and Economic Development; delivered by Henry Musasizi, Minister of Finance. 2026-06-11. Covers FY2026/27.
Desktop/Tax legislation Amendment Acts/Budget Speech FY2026.pdf
Status: verified. No page of this source is confirmed for this record by the audit; it is cited for context.
Read: tax measures for FY2026/27 (paragraphs 141 to 148, PDF pages 42 to 45, printed pages 38 to 41).
ACT-ITA-2026-21
Income Tax (Amendment) Act, 2026 (Act 21 of 2026)
Parliament of Uganda; Uganda Printing and Publishing Corporation. 2026-08-28. Covers In force from its commencement.
Desktop/Tax legislation Amendment Acts/Income Tax (Amendment) Act, 2026.pdf
Status: verified. Pages confirmed for this record in the source audit: 10 (PDF).
Acts Supplement No. 9 to the Uganda Gazette No. 83, Volume CXIX, dated 28 August 2026. Read in full (13 pages).