Uganda Revenue Authority v Norbrook Uganda Limited
High Court, Civil Appeal No. 36 of 2020. July to December 2025. Coram: Hon. Lady Justice Patricia Mutesi.
Customs Classification of Medicaments & Food supplements · Binding Effect of Tax Authority Clarifications · Legitimate Expectation · Estoppel
In 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.
The situation
A veterinary importer asked the Revenue Authority in 2011 how its products should be classified and was told in writing that they were medicaments, free of duty, VAT and withholding tax. It imported on that basis for about five years. A 2017 audit reclassified some products as supplements and assessed retrospectively, including UGX 2,919,094,217.51 on a multivitamin injection.
How it was resolved
The High Court held the importer had not proved the products were medicaments, but that the Revenue Authority was bound by its own written classifications for past imports: a change of position cannot reach back. Assessments on the products covered by the letters were vacated for 2012/13 to 2016/17; fresh assessments were ordered for one product the letters did not cover.
What a practitioner takes from it
Ask for classification in writing, product by product, and keep the reply: it protected every product it named and none that it did not.
Burden of proof on classification stays with the importer.