Uganda Revenue Authority v M-Kopa Uganda Limited
High Court, Civil Appeal No. 030 of 2019. July to December 2025. Coram: Hon. Lady Justice Susan Odongo.
Customs Duties and Exemptions · Customs Classification of Solar Home Systems · The Doctrine of Legitimate Expectation vis-à-vis Statutory Obligations
A solar home system came with a radio, a torch and a phone charger. Which parts were exempt from import duty?
The situation
A pay-as-you-go solar company imported home systems under an exemption for solar equipment. A post-clearance audit of 2013 to 2015 assessed UGX 429,603,357 on the accessories. The Tribunal set the assessment aside, partly because the company had acted on the Revenue Authority's own advice.
How it was resolved
The High Court allowed the Revenue Authority's appeal. Only the panel and the battery generate and store power; radios, torches, chargers and bulbs consume it, and being sold as one unit does not make them generation equipment. Advice from the authority cannot override the statute, so no legitimate expectation could arise.
What a practitioner takes from it
Exemptions are read narrowly and part by part, even for goods sold as a kit.
Written advice from the authority helps against a change of practice, but not against the plain words of the law (compare Cases 005, 011 and 012).