Wananchi Group Uganda Ltd v Uganda Revenue Authority
High Court, Civil Appeal No. 0053 of 2025. July to December 2025. Coram: Hon. Lady Justice Susan Odongo.
Import duty · Customs Classification of CAM cards under the EACCET
Is a pay-TV access card a television receiver, at 0% duty, or a part of one, at 25%?
The situation
A cable television operator imported conditional access cards from 2019 to 2021 at 0% duty as reception apparatus. In January 2022 the Revenue Authority reclassified them as television parts at 25% and assessed UGX 814,142,369 retrospectively. The Tribunal agreed.
How it was resolved
The High Court dismissed the appeal. The cards do not receive signals; they decrypt what the receiver has already received, so they are parts. With no overpayment there was no refund, and the operator had in any case relied on an Income Tax Act refund provision that does not apply to customs duty.
What a practitioner takes from it
Describe what a device actually does, not what system it belongs to.
Claim refunds under the law of the tax concerned.