Finn Church Aid Uganda v Uganda Revenue Authority
Tax Appeals Tribunal, Application No. 366 of 2024. July to December 2025. Coram: Ms. Crystal Kabajwara; Mrs. Kabakumba Masiko; Ms. Proscovia R. Nambi.
Liability to pay Stamp Duty · Stamp Duty on Employment and Supplier Contracts · Meaning of an Instrument for Stamp Duty Purposes
An NGO was assessed stamp duty on ten years of employment and supplier contracts, estimated from its PAYE and withholding returns.
The situation
An international NGO was assessed UGX 53,800,000 in stamp duty on employment and supplier agreements from 2014 to 2024. The Revenue Authority had counted them from PAYE and withholding tax returns.
How it was resolved
The Tribunal held that written employment and supply contracts are instruments chargeable at UGX 10,000 each, that non-profit status is irrelevant, and that the person executing the instrument bears the duty. But returns show that arrangements exist, not how many written agreements there are; the assessment was set aside and remitted to be recomputed on the actual agreements.
What a practitioner takes from it
Every written agreement executed in Uganda is dutiable unless exempt, including staff contracts.
An estimate must rest on the documents the tax attaches to.