Total Energies EP Uganda Limited v Uganda Revenue Authority
Tax Appeals Tribunal, Application No. 131 of 2024. July to December 2025. Coram: Ms. Crystal Kabajwara; Mrs. Stella Nyapendi Chombo; Mrs. Christine Katwe.
Taxpayer’s Duty to Provide Information · Penalty for Failure to Provide Information · Transfer Pricing Audits · Harmonious Interpretation of Tax Statutes
An oil company was fined USD 100,000 for not producing transfer pricing documents its French head office held.
The situation
During a transfer pricing audit begun in June 2023, the Revenue Authority asked an oil company for documents and set a final deadline of 31 December 2023, warning of a penalty of up to USD 500,000. The company supplied some on 10 January 2024, explaining much had to come from its French headquarters, and was assessed a penalty of USD 100,000.
How it was resolved
The Tribunal upheld the penalty. The licensee penalty in the Income Tax Act overrides only the amount of the general transfer pricing penalty, not the timelines, which are those the Commissioner sets by notice. The information was still outstanding at the hearing in 2025.
What a practitioner takes from it
For petroleum licensees, a missed information deadline costs USD 50,000 to 500,000, not UGX 50 million.
Start collecting group documents the day a transfer pricing audit opens.