Whistleblower (Ref: 170819150) v Uganda Revenue Authority
Court of Appeal, Civil Application No. 0527 of 2024. July to December 2025. Coram: Hon. Lady Justice Ketrah Kitariisibwa Katunguka.
Stay of Execution · Competence of Notice of Appeal in Tax Matters · Proof of Irreparable Damage · Security for Due Performance of the Decree
An informer's reward was cut from 10% to 5% between the tip and the recovery. Which rate applies?
The situation
An informer's tip led to the recovery of UGX 2.2 billion. The Revenue Authority paid a 5% reward under the 2019 law; the Tribunal ordered it to pay the 10% in force when the tip was given. The High Court reversed that, holding the law at the time of recovery applies. The informer appealed and sought a stay of the order to pay costs.
How it was resolved
The Court of Appeal refused the stay. The appeal raised an arguable question, but the notice of appeal was defective because it did not state the questions of law, the costs could be refunded if the appeal succeeded, and the security offered was too small.
What a practitioner takes from it
Which law governs an informer's reward, the one at the tip or at the recovery, is still before the Court of Appeal (compare Case 018).
Notices of appeal in tax matters must state the questions of law.