Century Bottling Co. Ltd v Uganda Revenue Authority
Tax Appeals Tribunal, Application No. 096 of 2022. July to December 2025. Coram: Mrs. Stella Nyapendi Chombo; Ms. Proscovia R. Nambi; Ms. Grace Safi.
Timelines for Additional Assessments · Proof of Discovery of New Information · Successive Additional Assessments · VAT on Imported Services · Distinct Supplies vis-à-vis Services Incidental to a Good · Tax Treatment of Finance Leases vis-à-vis Operating Leases · Deductibility and Deferral of Capital Allowances · Record Keeping Obligations for Tax Purposes · Commissioner’s Powers to Amend Prior Periods
An audit begun in 2016 produced assessments for 2013 onwards. Too late, said the company. New information, said the Revenue Authority.
The situation
A soft-drinks bottler was assessed UGX 10,214,827,515 after a transfer pricing audit of 2013 to 2018: VAT on installation and commissioning services from a foreign equipment maker, income tax from treating IT 'computer recharges' as finance leases, and tax from eliminating a UGX 18.9 billion carried-forward loss. It said the early years were time-barred and the assessments duplicated an earlier audit.
How it was resolved
The Tribunal upheld everything. Documents supplied late, after many extensions, were new information, so the three-year limit did not apply; the law allows successive additional assessments; the post-import services were separate supplies taxed by reverse charge; the IT charges were finance leases, deductible only as interest; and records must be kept until an audit closes, even beyond five years.
What a practitioner takes from it
Every extension you ask for during an audit can later justify an assessment outside the normal time limit.
Keep records for any period under audit until the audit closes.
Accounting labels (IAS 17, IFRS 16) do not decide tax treatment.
What could change
A statutory deadline for completing an audit would protect taxpayers and the Revenue Authority alike from disputes about years a decade old.