Machame Estates Limited v Uganda Revenue Authority
Tax Appeals Tribunal, Application No. 49 of 2025. July to December 2025. Coram: Ms. Crystal Kabajwara; Ms. Proscovia R. Nambi; Mrs. Stella Nyapendi Chombo.
Withholding Tax on Purchase of a Business Asset · Computation of Withholding Tax on a Land Swap Arrangement
Two companies swapped land. The Revenue Authority said one of them had 'purchased' property and should have withheld 6%.
The situation
A company exchanged land in Luwero for land on Prince Charles Drive in December 2023. The Revenue Authority assessed withholding tax of UGX 888,000,000 at 6% of the Kampala land's value, UGX 14.8 billion, as set by the Chief Government Valuer for stamp duty.
How it was resolved
The Tribunal held that a swap is a purchase: the company became owner, and the other party disposed of its land for consideration in kind, so tax should have been withheld. But the base is the market value of what the company gave, the Luwero land, not of what it received. The assessment was set aside and the Revenue Authority told to reassess on that basis.
What a practitioner takes from it
Swaps and other payments in kind carry withholding tax; value the consideration given.
The Tribunal may confirm a liability and still reject the figure.
The Digest's summary sets the assessment aside and orders a reassessment, yet ends "dismissed with costs". We report the substance. Check the ruling.