G4S Secure Solutions Uganda Limited v Uganda Revenue Authority
Tax Appeals Tribunal, Application No. 98 of 2024. July to December 2025. Coram: Ms. Crystal Kabajwara; Ms. Proscovia R. Nambi; Mrs. Stella Nyapendi Chombo.
Employment Benefits as Part of Employment Income · Pay As You Earn on Meals · The Equal Terms Condition of Employment Benefits
A security firm's guards at some client sites were fed by caterers the client paid for through the firm. Is that a taxable benefit?
The situation
After an audit of 2018 to 2022, the parties settled most issues in mediation but left PAYE of UGX 1,795,735,201 on meals given to guards deployed at certain client premises. The firm said it only arranged the meals at clients' request and recharged their cost.
How it was resolved
The Tribunal held the meals were a benefit provided under an arrangement with the employer, so PAYE applied, whoever ultimately paid. They were not exempt because they were not available to all full-time employees on equal terms. But the Revenue Authority's blanket computation ignored each guard's own tax position, so the assessment was set aside to be recomputed from a list of the guards who benefited.
What a practitioner takes from it
A benefit arranged by the employer is taxable even if a client pays for it.
Equal terms means all full-time staff, not all staff at a given site.