International School of Uganda v Uganda Revenue Authority
Tax Appeals Tribunal, Application No. 188 of 2024. July to December 2025. Coram: Ms. Crystal Kabajwara; Mrs. Stella Nyapendi Chombo; Ms. Proscovia R. Nambi.
Withholding Tax on Interest Payments · Withholding Tax as a Final Tax · Exempt Organizations
An exempt school earned interest on fixed deposits. Was the 15% the bank withheld the end of it?
The situation
An international school with an income tax exemption earned UGX 1,053,010,485 in fixed-deposit interest from 2016 to 2020, on which its bank withheld 15%. The Revenue Authority assessed UGX 315,905,143, arguing withholding is final only on government securities.
How it was resolved
The Tribunal allowed the application. Section 139(a) has two alternative limbs, and the second covers interest paid by a financial institution to an exempt organisation. The school held a ruling that it was exempt, so the tax withheld was final and no further tax could be imposed.
What a practitioner takes from it
Exempt organisations should keep their exemption ruling current: it made the withholding final here.
Read 'or' in a list as setting out alternatives.