Medisell Uganda Limited v Uganda Revenue Authority
Tax Appeals Tribunal, TAT Application Nos. 51 and 72 of 2023. 4 August 2026.
Variances are not sales
An audit found differences in a medical distributor's cost of sales and treated them as undeclared income.
The situation
After a comprehensive audit, a medical distributor contested a revised demand of about UGX 1.05 billion. The Revenue Authority treated accounting variances in cost of sales as undeclared income and taxable supplies.
How it was resolved
The Tribunal ruled against the Revenue Authority, blocking collection of UGX 1,006,376,995: accounting differences, reclassifications, corrected errors and currency translation are not automatically income, and a VAT variance must be tied to an actual supply.
What a practitioner takes from it
Explain every variance with documents; the authority must then show a real transaction (compare Cases 002 and 029).
The ruling is listed on the Tribunal's website, but we have not read it. This page rests on a Daily Monitor report we could see only in part. Read the ruling before relying on this.