Aggreko International Services Limited v Uganda Revenue Authority
Tax Appeals Tribunal, Application No. 103 of 2025. July to December 2025. Coram: Ms. Crystal Kabajwara; Ms. Proscovia R. Nambi; Mrs. Stella Nyapendi Chombo.
Applicability of the Requirement to Pay 30% of the Tax in Dispute
The 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?
The situation
A former power producer received a reminder in May 2023 to pay UGX 44.6 billion in various taxes. It challenged the way the Revenue Authority had allocated its payments, which left UGX 33,718,915,000 outstanding on its ledger. The authority said it must first deposit 30%, UGX 10.1 billion.
How it was resolved
The Tribunal dismissed the objection. The deposit presupposes an assessment that has been objected to; there was none, only a dispute about allocating payments. And the dispute was purely one of law, which falls within the Fuelex exception, under which applying the deposit would be unconstitutional.
What a practitioner takes from it
A dispute about how payments were allocated, or any purely legal question, may not need the 30% deposit.
Frame the dispute precisely: it decides whether you pay to be heard.