Tradeworth Establishment Limited v Uganda Revenue Authority
Tax Appeals Tribunal, Application No. 338 of 2025. July to December 2025. Coram: Ms. Crystal Kabajwara; Ms. Grace Safi; Mr. Willy Nangosyah.
Zero-Rated Supplies · Standard-Rated Supplies · Equal Treatment of Supplies within the East African Community
Rice grown in Uganda is zero-rated. An importer was charged 18% VAT on rice from Tanzania for five years.
The situation
An importer paid 18% VAT on rice from Tanzania from 2017 to 2022, under protest. The Attorney General twice advised that EAC rice must be treated like Ugandan rice; the Revenue Authority verified a refund of UGX 7,563,332,543, then declined it, saying the importer had recovered the VAT through output tax, and applied a 6% mark-up to leave a small balance payable.
How it was resolved
The Tribunal held rice is a cereal, that EAC-origin rice must be treated as Ugandan rice is, so the standard-rating was unlawful; the authority had no evidence the importer charged VAT on its sales and no basis for the 6% mark-up, acting 'with impunity'. It ordered a refund with interest at 2% a month compounded, UGX 100 million in damages and costs.
What a practitioner takes from it
EAC goods are entitled to the same VAT treatment as local goods.
A verified refund cannot be withdrawn on assumptions.
What could change
Applying an Attorney General's opinion across the board, once the authority accepts it, would avoid a case for every importer.