Slunko (U) Limited v Uganda Revenue Authority
Tax Appeals Tribunal, Application No. 28 of 2025. July to December 2025. Coram: Ms. Crystal Kabajwara; Mr. Willy Nangosyah; Ms. Rosemary Najjemba.
Allowable Deductions in Rental Income · Capital Expenditure vis-à-vis Revenue Expenditure · Capping of Allowable Deductions
Can a landlord company deduct last year's losses against this year's rent?
The situation
A property company filed a nil return for 2022/23 despite rental income. After objection it was assessed UGX 15,487,933. It argued the 50% cap on deductions against rent should not apply to carried-forward losses, capital expenditure or its industrial building deduction.
How it was resolved
The Tribunal dismissed the application. Against rental income, only revenue expenditure incurred in the same year is deductible, and it is capped at 50%; carried-forward losses are not deductible at all, and building allowances count as revenue items within the cap.
What a practitioner takes from it
Rental income stands alone: losses from earlier years do not carry into it (contrast Case 028, for business income).