JK Country Homes Limited v Uganda Revenue Authority
Tax Appeals Tribunal, Application No. 41 of 2024. July to December 2025. Coram: Ms. Crystal Kabajwara; Mrs. Kabakumba Masiko; Mr. Willy Nangosyah.
Taxation of Rental Income · Rental Income Deductions
A company claimed interest on a loan its shareholder had taken out personally, on property registered in the shareholder's name.
The situation
A real-estate company was assessed UGX 17,286,922 for 2021/22 after the Revenue Authority capped its expenses against rental income at 75%, the individual rule. The company said a company's rental expenses are deductible in full, including interest on a bank loan.
How it was resolved
The Tribunal dismissed the application. The loan was in the shareholder's name, for other purposes; no board resolution or reimbursement showed the company assumed it; the company had no bank account; and the property was registered to the shareholder. The rent was the individual's, and the 75% cap applied.
What a practitioner takes from it
A company claims only what it legally owes and owns: put loans and property in the company's name if the company is to deduct.
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