Kampala Club v Uganda Revenue Authority
High Court, Civil Appeal No. 0115 of 2023. July to December 2025. Coram: Hon. Lady Justice Susan Odongo.
Taxable Supplies · VAT on Annual Subscription and Registration Fees · Business Activities vis-à-vis Leisure Activities
Is a members' club's annual subscription payment for a service, and so subject to VAT?
The situation
A non-profit members' club, founded in 1912 and running health and sports facilities for members only, was assessed VAT of UGX 166,541,103 on annual subscriptions and registration fees for 2020 and 2021. The Tribunal held the fees were payment for services.
How it was resolved
The High Court allowed the appeal and quashed the assessments. A taxable supply must be part of a business activity; the club's activities were recreational and communal, not run for profit. The subscription secured membership rights rather than paying for a discrete service, and covering costs is not the same as selling. The Court also noted that in over a century no VAT had been charged on these fees.
What a practitioner takes from it
For VAT, ask first whether there is a business activity at all; consideration alone is not enough.
How membership rights are written in the constitution can decide the case.