Standard Chartered Bank v Uganda Revenue Authority
Tax Appeals Tribunal, Not given in the report. Reported 29 July 2026.
Correspondent bank fees
A bank paid fees to foreign correspondent banks and passed the cost on to customers. Who owed the withholding tax?
The situation
The Revenue Authority assessed about UGX 1.107 billion in withholding tax on transaction and account maintenance fees a bank paid to correspondent banks in six countries from 2016 to 2019. The bank said customers bore the fees, that maintenance fees were exempt interest, that the treaties were misapplied and that part of the assessment was out of time.
How it was resolved
The Tribunal dismissed the application. The bank received and paid for the services, so it had to withhold whoever bore the cost; the fees were not shown to be interest; under the treaties they were technical service fees, not business profits; and information from an earlier refund audit allowed the later assessment.
What a practitioner takes from it
Passing a cost on to customers does not pass on the withholding obligation.
A refund audit can open the door to an additional assessment.