TaxIntellilytics Stories

The Casebook

The Registry

Forty-seven decided Ugandan tax disputes: where the rule, the practice or the system did not fit the facts, what was argued and what was held. Pull a file off the wall, or refile the whole wall and watch the pattern change.

File the wall by

Take the bench14 disputes, both sides, your stamp

Matching files slide out of their holes

How thick is a file

UGX 15mUGX 500mUGX 33.7bnNo sum reported

Thickness is the sum at stake on a log scale, so each step up is the same multiple of money.

The tape and the letter on the tag

  • TFor the taxpayer
  • UFor the Revenue Authority
  • PPart of each
  • SSent back to recompute

Read this before counting

This wall is not a win rate. These are 47 selected rulings, and 30 come from the Revenue Authority's own digest. A hole left empty is room for the next ruling, not a gap in the record.

The same files, as a list

What it was about
Who it went for

47 cases

Each file is tied with the Registry’s tape, its colour who the ruling went for. They are styled as court files for reading, and are not official records.

  1. No. 001In the Tax Appeals TribunalApplication No. 73 of 2026The ninetieth dayMunyanga Development LimitedvUganda Revenue AuthorityThe Revenue Authority decided an objection a few hours too late. The taxpayer had already used the one remedy the law gives for silence.TaxTax procedureDecided30 June 2026In disputeUGX 1.81bnHeldAssessment of UGX 1,808,625,194 declared voidDecided for the taxpayer
  2. No. 002In the Tax Appeals TribunalApplication No. 060 of 2020When the VAT returns and the accounts don't agreeEricsson ABvUganda Revenue AuthorityA gap between sales in the VAT returns and sales in the income tax returns became a UGX 9.7 billion VAT assessment, collected from the bank before the objection window had closed. Seven years later, most of it came back.TaxVATDecided29 May 2026In disputeUGX 9.72bnHeldVAT principal cut from UGX 9,718,600,521 to UGX 2,580,634,340; UGX 7,707,506,228 to be refunded with the deposit, at 2% a monthDecided for the taxpayer
  3. No. 003In the Tax Appeals TribunalNot given in the reportBilled abroad, consumed at homeAllied Beverages LimitedvUganda Revenue AuthorityMarketing services were invoiced to a foreign affiliate and zero-rated as exports. The Tribunal looked at where the adverts ran.TaxVATDecidedReported 29 July 2025In disputeUGX 9.70bnHeldAssessment of UGX 9.7 billion (about USD 2.7 million) upheld; taxpayer to pay 80% of costsDecided for the Revenue Authority
  4. No. 004In the Tax Appeals TribunalApplication No. 36 of 2024Gross or net interest?Rwenzori Commodities LimitedvUganda Revenue AuthorityThe 30% interest cap: does it apply to all the interest a group company pays, or only to what is left after the interest it earns?TaxIncome taxDecided30 July 2025In disputeUGX 521mHeldThe Revenue Authority's reading upheld: the cap applies to gross interestDecided for the Revenue Authority
  5. No. 005In the High CourtCivil Appeal No. 0042 of 2023Fruit pulp, and a change of mindBritania Allied Industries LimitedvUganda Revenue AuthorityFor years the Revenue Authority cleared mango and guava pulp under a duty remission scheme. Then an audit reclassified it and sent a bill for the past.TaxCustomsDecidedJuly to December 2025In disputeUGX 1.25bnHeldAppeal allowed; retrospective reclassification held unlawfulDecided for the taxpayer
  6. No. 006In the High CourtMisc. Application No. 1606 of 2025The application that was never filedChefette Catering LtdvUganda Revenue AuthorityA company's lawyers did not file its Tribunal application. By the time it found out, every deadline had passed.TaxIncome tax and VATDecidedJuly to December 2025In disputeUGX 1.41bnHeldStay refused; the appeal was out of time and in the wrong courtDecided for the Revenue Authority
  7. No. 007In the High CourtCivil Appeal No. 0014 of 2022Thirty percent of what?Nile Breweries LimitedvUganda Revenue Authority, Stanbic Bank and Standard CharteredTo stop collection while a dispute is heard, a taxpayer pays 30% of the tax in dispute. A brewer argued what it had already paid should count.TaxVAT and exciseDecidedJuly to December 2025In disputeNot reportedHeldContempt finding set aside; 30% deposit held to apply to the additional assessmentSplit decision
  8. No. 008In the Court of AppealMisc. Application No. 79 of 2020First appeal or second?Housing Finance Bank LtdvUganda Revenue AuthorityIs an appeal from the Tribunal to the High Court a first appeal or a second? The answer decides whether a taxpayer can go further.TaxTax procedureDecidedJuly to December 2025In disputeNot reportedHeldCertificate granted to take the jurisdiction question to the Supreme CourtDecided for the taxpayer
  9. No. 009In the High CourtCivil Appeal No. 0115 of 2023The club subscriptionKampala ClubvUganda Revenue AuthorityIs a members' club's annual subscription payment for a service, and so subject to VAT?TaxVATDecidedJuly to December 2025In disputeUGX 167mHeldAppeal allowed; VAT assessments quashedDecided for the taxpayer
  10. No. 010In the High CourtCivil Appeal No. 030 of 2019What counts as solar equipment?Uganda Revenue AuthorityvM-Kopa Uganda LimitedA solar home system came with a radio, a torch and a phone charger. Which parts were exempt from import duty?TaxCustomsDecidedJuly to December 2025In disputeUGX 430mHeldRevenue Authority's appeal allowed; duty due on the accessoriesDecided for the Revenue Authority
  11. No. 011In the High CourtCivil Appeal No. 36 of 2020Medicine or supplement?Uganda Revenue AuthorityvNorbrook Uganda LimitedIn 2011 the Revenue Authority wrote that a veterinary multivitamin was a medicament. Six years later it assessed duty as if it were a food supplement.TaxCustomsDecidedJuly to December 2025In disputeUGX 2.92bnHeldAssessments vacated where URA's letters applied; fresh assessment for one productSplit decision
  12. No. 012In the High CourtCivil Appeal No. 0057 of 2021The cough lozengeUganda Revenue AuthorityvTATA Uganda LimitedHerbal cough lozenges were cleared duty-free as medicine for four years, then reclassified as sweets.TaxCustomsDecidedJuly to December 2025In disputeUGX 727mHeldRevenue Authority's appeal dismissed; assessment stays set asideDecided for the taxpayer
  13. No. 013In the High CourtCivil Appeal No. 0053 of 2025The decoder cardWananchi Group Uganda LtdvUganda Revenue AuthorityIs a pay-TV access card a television receiver, at 0% duty, or a part of one, at 25%?TaxCustomsDecidedJuly to December 2025In disputeUGX 814mHeldAppeal dismissed; 25% duty upheldDecided for the Revenue Authority
  14. No. 014In the Court of AppealCivil Application No. 0527 of 2024Five percent or ten?Whistleblower (Ref: 170819150)vUganda Revenue AuthorityAn informer's reward was cut from 10% to 5% between the tip and the recovery. Which rate applies?TaxInformer rewardDecidedJuly to December 2025In disputeUGX 119mHeldStay refused; the main appeal on the reward rate is pendingDecided for the Revenue Authority
  15. No. 015In the Court of AppealCivil Appeal No. 105 of 2018The duty-free sugarWorld Point Group LimitedvAttorney General and Uganda Revenue AuthorityIn a 2011 sugar shortage, importers were licensed to bring in sugar duty-free. One was delayed at Mombasa and re-exported part of it.TaxCustomsDecidedJuly to December 2025In disputeUGX 206mHeldBoth appeals dismissed; refund of tax on sugar sold locally standsSplit decision
  16. No. 016In the Tax Appeals TribunalMisc. Application No. 06 of 2025The settlement it signedAdraa Agriculture CollegevUganda Revenue AuthorityA college settled its tax dispute through ADR, did not pay, then asked the Tribunal to review the settlement.TaxIncome taxDecidedJuly to December 2025In disputeUGX 61mHeldInjunction refused; the ADR settlement bindsDecided for the Revenue Authority
  17. No. 017In the Tax Appeals TribunalApplication No. 103 of 2025No assessment, no depositAggreko International Services LimitedvUganda Revenue AuthorityThe Revenue Authority's ledger showed UGX 33.7 billion owed because of how it had allocated payments. Must the company deposit 30% to challenge that?TaxTax procedureDecidedJuly to December 2025In disputeUGX 33.7bnHeldObjection dismissed; no 30% deposit requiredDecided for the taxpayer
  18. No. 018In the Tax Appeals TribunalApplication No. 112 of 2021The informer who was rightBlack CobvUganda Revenue AuthorityAn informer reported a brewer's related-party dealings. The Revenue Authority later said the tip had not helped.TaxInformer rewardDecidedJuly to December 2025In disputeUGX 4.10bnHeldApplication allowed; balance of reward ordered paidDecided for the taxpayer
  19. No. 019In the Tax Appeals TribunalApplication No. 096 of 2022The bottler and the audit that took yearsCentury Bottling Co. LtdvUganda Revenue AuthorityAn audit begun in 2016 produced assessments for 2013 onwards. Too late, said the company. New information, said the Revenue Authority.TaxVAT and income taxDecidedJuly to December 2025In disputeUGX 10.2bnHeldAssessments of UGX 10.2 billion upheldDecided for the Revenue Authority
  20. No. 020In the Tax Appeals TribunalApplication No. 213 of 2023The wrong columnExp Momentum (U) LimitedvUganda Revenue AuthorityFiling an objection online, a company typed the disputed amount into the 'not in dispute' column.TaxIncome tax and VATDecidedJuly to December 2025In disputeUGX 264mHeldPartly remitted, partly upheld, penalty set asideSplit decision
  21. No. 021In the Tax Appeals TribunalApplication No. 366 of 2024Stamp duty on every contractFinn Church Aid UgandavUganda Revenue AuthorityAn NGO was assessed stamp duty on ten years of employment and supplier contracts, estimated from its PAYE and withholding returns.TaxStamp dutyDecidedJuly to December 2025In disputeUGX 54mHeldLiability confirmed; assessment remitted to recomputeLiability confirmed, figure sent back to recompute
  22. No. 022In the Tax Appeals TribunalApplication No. 98 of 2024Meals for the guardsG4S Secure Solutions Uganda LimitedvUganda Revenue AuthorityA security firm's guards at some client sites were fed by caterers the client paid for through the firm. Is that a taxable benefit?TaxPAYEDecidedJuly to December 2025In disputeUGX 1.80bnHeldPAYE liability confirmed; recomputation per employee orderedLiability confirmed, figure sent back to recompute
  23. No. 023In the Tax Appeals TribunalApplication No. 188 of 2024The school's fixed depositInternational School of UgandavUganda Revenue AuthorityAn exempt school earned interest on fixed deposits. Was the 15% the bank withheld the end of it?TaxIncome taxDecidedJuly to December 2025In disputeUGX 316mHeldApplication allowed; withholding tax was finalDecided for the taxpayer
  24. No. 024In the Tax Appeals TribunalApplication No. 41 of 2024The loan in the shareholder's nameJK Country Homes LimitedvUganda Revenue AuthorityA company claimed interest on a loan its shareholder had taken out personally, on property registered in the shareholder's name.TaxIncome tax (rental)DecidedJuly to December 2025In disputeUGX 17mHeldApplication dismissed; individual rental rules appliedDecided for the Revenue Authority
  25. No. 025In the Tax Appeals TribunalApplication No. 300 of 2024A hotel let, or a hotel business?Lake Victoria Hotel LimitedvUganda Revenue AuthorityA hotel company leased its whole hotel to an operator for USD 850,000 a year. Rent, or business income?TaxIncome tax (rental)DecidedJuly to December 2025In disputeUGX 118mHeldRental characterisation upheldDecided for the Revenue Authority
  26. No. 026In the Tax Appeals TribunalApplication No. 49 of 2025The land swapMachame Estates LimitedvUganda Revenue AuthorityTwo companies swapped land. The Revenue Authority said one of them had 'purchased' property and should have withheld 6%.TaxWithholding taxDecidedJuly to December 2025In disputeUGX 888mHeldLiability confirmed; assessment set aside to reassess on the right valueLiability confirmed, figure sent back to recompute
  27. No. 027In the Tax Appeals TribunalApplication No. 135 of 2024The export agentsNile Breweries LimitedvUganda Revenue AuthorityA brewer sold beer at its factory gate to two companies that exported it, and treated the sales as zero-rated exports.TaxVAT and exciseDecidedJuly to December 2025In disputeUGX 18.5bnHeldUGX 18.5 billion upheld; stays of collection refused in 2026Decided for the Revenue Authority
  28. No. 028In the Tax Appeals TribunalApplication No. 12 of 2024Losses and the interest capSai Office Supplies LimitedvUganda Revenue AuthorityDoes a company deduct its carried-forward losses when working out the 'tax EBITDA' that caps its interest?TaxIncome taxDecidedJuly to December 2025In disputeUGX 292mHeldApplication dismissed; losses reduce tax EBITDADecided for the Revenue Authority
  29. No. 029In the Tax Appeals TribunalApplication No. 82 of 2024The best judgment that wasn'tShahil Investments LimitedvUganda Revenue AuthorityAfter raids, three audits and an investigation, a hardware distributor was assessed UGX 2.8 billion on estimated sales and alleged invoice trading.TaxVAT and income taxDecidedJuly to December 2025In disputeUGX 2.79bnHeldAssessments of UGX 2.8 billion vacatedDecided for the taxpayer
  30. No. 030In the Tax Appeals TribunalApplication No. 28 of 2025Rental losses and the 50% capSlunko (U) LimitedvUganda Revenue AuthorityCan a landlord company deduct last year's losses against this year's rent?TaxIncome tax (rental)DecidedJuly to December 2025In disputeUGX 15mHeldApplication dismissedDecided for the Revenue Authority
  31. No. 031In the Tax Appeals TribunalApplication No. 131 of 2024The documents from ParisTotal Energies EP Uganda LimitedvUganda Revenue AuthorityAn oil company was fined USD 100,000 for not producing transfer pricing documents its French head office held.TaxIncome tax (penalty)DecidedJuly to December 2025In disputeUSD 100,000HeldPenalty of USD 100,000 upheldDecided for the Revenue Authority
  32. No. 032In the Tax Appeals TribunalApplication No. 338 of 2025Rice from TanzaniaTradeworth Establishment LimitedvUganda Revenue AuthorityRice grown in Uganda is zero-rated. An importer was charged 18% VAT on rice from Tanzania for five years.TaxVATDecidedJuly to December 2025In disputeUGX 7.56bnHeldRefund ordered with 2% monthly interest and UGX 100 million damagesDecided for the taxpayer
  33. No. 033In the Tax Appeals TribunalApplication No. 224 of 2024The remission revoked without reasonsYogi Steels LimitedvUganda Revenue AuthorityA steel maker bought wire rods relying on a 12-month duty remission. Two weeks later the remission was revoked, without a word of explanation.TaxCustomsDecidedJuly to December 2025In disputeNot reportedHeldRevocation unlawful; duty remission and refund of security orderedDecided for the taxpayer
  34. No. 034In the Tax Appeals TribunalApplication No. 54 of 2025The share sale abroadKuku Foods Uganda LimitedvUganda Revenue AuthorityShareholders abroad sold a Ugandan fast-food company. The Revenue Authority taxed the Ugandan company itself.TaxIncome tax (capital gains)Decided11 May 2026In disputeUGX 4.24bnHeldLiability confirmed; UGX 4.2 billion assessment set aside for revaluationLiability confirmed, figure sent back to recompute
  35. No. 035In the Tax Appeals TribunalApplication No. 330 of 2025The trademark in MauritiusMini Bakeries Uganda LimitedvUganda Revenue AuthorityA bakery paid 2% of sales in royalties to a Mauritian company that owned its brand but did nothing to build it.TaxIncome tax (transfer pricing)Decided21 August 2026In disputeNot reportedHeldTransfer pricing adjustments upheldDecided for the Revenue Authority
  36. No. 036In the Court of AppealCivil Appeal No. 220 of 2022Interest that was never paidATC Uganda LimitedvUganda Revenue AuthorityInterest on a shareholder loan was added to the principal for five years instead of being paid. Was it 'paid' for withholding tax?TaxWithholding taxDecided27 March 2026In disputeUGX 24.2bnHeldAppeal dismissed; about UGX 24.2 billion upheldDecided for the Revenue Authority
  37. No. 037In the Tax Appeals TribunalApplication No. 75 of 2019Head office chargesSMEC International LtdvUganda Revenue AuthorityAn engineering firm's Ugandan branch deducted head office and regional charges that at times exceeded 90% of its revenue.TaxIncome taxDecided15 November 2024In disputeNot reportedHeldDisallowance upheld; withholding tax credit remitted for offsetDecided for the Revenue Authority
  38. No. 038In the High CourtCivil Appeal No. 0039 of 2022Billed abroad: the first roundAllied Beverage Company LtdvUganda Revenue AuthorityFor 2016 to 2020, a marketing agent's services to a US affiliate were assessed VAT of UGX 17.4 billion. The High Court overturned the Tribunal.TaxVATDecidedSeptember 2024In disputeUGX 17.4bnHeldAppeal allowed; UGX 17.4 billion assessment overturnedDecided for the taxpayer
  39. No. 039In the High CourtMiscellaneous Cause No. 26 of 2024Five companies, one taxpayerUganda Revenue AuthorityvCrane Autos Ltd (in liquidation) and 5 othersAfter an investigation began, a motor dealer went into liquidation and shares moved between related companies. The court treated all five as one.TaxTax recoveryDecided29 July 2024In disputeUGX 20.0bnHeldCorporate veil lifted; companies and owners jointly liableDecided for the Revenue Authority
  40. No. 040In the Tax Appeals TribunalCase No. 65 of 2018The price of green leafBondo Tea Estates LtdvUganda Revenue AuthorityA tea estate sold green leaf to a related factory. The Revenue Authority said the price was too low, using prices it collected two years later.TaxIncome tax (transfer pricing)DecidedMarch 2021In disputeUGX 544mHeldAppeal allowed; price adjustment set asideDecided for the taxpayer
  41. No. 041In the Tax Appeals TribunalNot given in the reportCorrespondent bank feesStandard Chartered BankvUganda Revenue AuthorityA bank paid fees to foreign correspondent banks and passed the cost on to customers. Who owed the withholding tax?TaxWithholding taxDecidedReported 29 July 2026In disputeUGX 1.11bnHeldApplication dismissed; UGX 1.1 billion upheldDecided for the Revenue Authority
  42. No. 042In the High CourtNot given in the reportRelief food, and a silent CommissionerUganda Revenue AuthorityvPentecostal Assemblies of GodAn aid organisation's refugee food imports were reassessed for VAT. It objected; the Commissioner did not reply in thirty days.TaxVAT and customsDecided30 April 2026In disputeUGX 123mHeldObjection deemed allowed; refund with interest and UGX 65 million damagesDecided for the taxpayer
  43. No. 043In the Tax Appeals TribunalNot given in the reportADR does not stop the clockAfrica Global Logistics Uganda LtdvUganda Revenue AuthorityA company went to ADR after its objection failed, then filed at the Tribunal within thirty days of the ADR decision.TaxTax procedureDecided12 August 2025In disputeNot reportedHeldApplication dismissed as out of timeDecided for the Revenue Authority
  44. No. 044In the Tax Appeals TribunalTAT Application Nos. 51 and 72 of 2023Variances are not salesMedisell Uganda LimitedvUganda Revenue AuthorityAn audit found differences in a medical distributor's cost of sales and treated them as undeclared income.TaxVAT and income taxDecided4 August 2026In disputeUGX 1.01bnHeldAssessment of UGX 1 billion blockedDecided for the taxpayer
  45. No. 045In the Tax Appeals TribunalTAT Application No. 083 of 2026A settlement the authority tried to undoContinental Tobacco Uganda LimitedvUganda Revenue AuthorityAfter settling a tobacco company's assessments through ADR, the Revenue Authority reopened them and sealed its premises.TaxVAT and income taxDecided24 July 2026In disputeUGX 10.1bnHeldSettlement held binding; URA ordered to unseal the premisesDecided for the taxpayer
  46. No. 046In the Tax Appeals TribunalNot given in the reportA credit note is not a write-offDHL Supply Chain International LtdvUganda Revenue AuthorityA logistics subsidiary could not pay its parent for imported IT and management services, so it issued credit notes cancelling them.TaxVATDecidedReported 13 June 2022In disputeUGX 1.48bnHeldVAT of UGX 1.48 billion ordered paidDecided for the Revenue Authority
  47. No. 047In the High CourtNot given in the reportThe cost of finding oilHeritage Oil and Gas LimitedvUganda Revenue AuthorityWhen an oil explorer sold its Ugandan interests, were exploration costs part of the cost base for capital gains?TaxIncome tax (capital gains)Decided23 December 2024In disputeabout USD 45 millionHeldRefund of about USD 45 million ordered; URA reported likely to appealDecided for the taxpayer

Where the cases come from

Thirty of the cases come from the Uganda Revenue Authority's own Case Digest (Volume XI, decisions of July to December 2025), which summarises rulings the Authority was a party to; the rest from advisers' case summaries, case-law databases and the press. Each case names its sources. They are retold in our words, in the same shape, with a label on every section for the kind of evidence it is. Read the full ruling before relying on any of them.

This is not every ruling. The Tribunal decides hundreds of applications a year, and most are not published in summary. The book grows with each Digest, each published ruling and each case a professional sends in.

Last updated 2026-11-03.