The Tax Month · October 2026
The registers
Every legal citation, data source and derived calculation behind the October issue. Expand a row to see the full record, or download the raw JSON.
Legal register
Raw JSON ↓10 legal propositions, each traced to a provision
Every legal statement made anywhere in the October issue maps to one row here: the instrument, the exact provision, its status (law in force vs. draft vs. negotiating text), and what it does and doesn't support.
Instrument
Income Tax Act, Chapter 338
Jurisdiction
Uganda
Effective / draft date
Consolidated text current to 2024-12-23
Proposition supported
A non-resident deriving dividends, interest, royalties, rent, a natural resource payment or a management charge from a Ugandan source is taxed on the gross amount at 15%.
Limitations
Rate is set by cross-reference to Schedule 4 Part V, para. 1, not stated in s.82 itself. No specific Uganda tax treaty has been checked for an override.
Notes
General-purpose provision for payments not caught by s.84 or s.86.
Source
Uganda Legal Information Institute / Laws.Africa consolidation
Accessed
2026-09-29
Instrument
Income Tax Act, Chapter 338
Jurisdiction
Uganda
Effective / draft date
Consolidated text current to 2024-12-23
Proposition supported
A payment under a "Ugandan source services contract" to a non-resident is taxed at 15% of the gross amount.
Limitations
Rate is set by cross-reference to Schedule 4 Part V, para. 1. Whether a specific real payment qualifies as a "Ugandan source services contract" depends on its exact facts, not resolved here.
Notes
The provision this issue's opening hypothetical would most likely fall under.
Source
Uganda Legal Information Institute / Laws.Africa consolidation
Accessed
2026-09-29
Instrument
Income Tax Act, Chapter 338
Jurisdiction
Uganda
Effective / draft date
Consolidated text current to 2024-12-23
Proposition supported
A non-resident earning income from a digital service delivered over the internet, an electronic network or an online platform to a Uganda customer is taxed at 5% of the gross amount.
Limitations
Rate is set by cross-reference to Schedule 4 Part V, para. 3. The platform/customer-location test in s.86(2)-(3) has to be met on the facts.
Notes
Named examples in s.86(3): online advertising, data services, online-marketplace intermediation.
Source
Uganda Legal Information Institute / Laws.Africa consolidation
Accessed
2026-09-29
Instrument
Income Tax Act, Chapter 338
Jurisdiction
Uganda
Effective / draft date
Consolidated text current to 2024-12-23
Proposition supported
A Ugandan party to a services agreement with a non-resident not already caught by s.84 must notify the Commissioner General in writing within 30 days, or become personally liable for the non-resident's tax.
Limitations
Whether s.138 notifications are administratively reconciled against s.84 withholding is not publicly documented -- not established from public evidence.
Notes
The identification mechanism for the arrangements s.84 doesn't already catch automatically.
Source
Uganda Legal Information Institute / Laws.Africa consolidation
Accessed
2026-09-29
Instrument
Income Tax Act, Chapter 338
Jurisdiction
Uganda
Effective / draft date
Consolidated text current to 2024-12-23
Proposition supported
Sets the 15% rate applied under ss.81, 82, 83 and 84 (excluding government-securities interest).
Limitations
None identified.
Source
Uganda Legal Information Institute / Laws.Africa consolidation
Accessed
2026-09-29
Instrument
Income Tax Act, Chapter 338
Jurisdiction
Uganda
Effective / draft date
Consolidated text current to 2024-12-23
Proposition supported
Sets the 5% rate applied under s.86 to non-resident digital services.
Limitations
None identified.
Source
Uganda Legal Information Institute / Laws.Africa consolidation
Accessed
2026-09-29
Instrument
Zero Draft of the UN Framework Convention on International Tax Cooperation
Jurisdiction
International (UN)
Effective / draft date
Draft dated 2026-07-21
Proposition supported
Would require competent authorities to exchange foreseeably relevant tax information, subject to safeguards.
Limitations
The entire article is enclosed in square brackets in the draft text -- negotiators have not yet agreed it.
Notes
Distinct from Article 10 (Mutual Administrative Assistance), which is not bracketed.
Source
Co-Lead's Zero Draft, read directly from the source PDF
Accessed
2026-09-30
Instrument
Draft Protocol I to the UN Framework Convention -- Taxation of Income from Cross-Border Services
Jurisdiction
International (UN)
Effective / draft date
Draft dated 2026-07-20
Proposition supported
Would let the source state tax fees for services paid to a resident of another State Party, capped at a percentage of the gross amount.
Limitations
The cap itself is an empty bracket -- "[ ] per cent of the gross amount" -- not yet negotiated.
Notes
The provision that would apply to an ordinary cross-border consulting/professional-service payment.
Source
Co-Lead's Draft Protocol I, read directly from the source PDF
Accessed
2026-09-30
Instrument
Draft Protocol I to the UN Framework Convention -- Taxation of Income from Cross-Border Services
Jurisdiction
International (UN)
Effective / draft date
Draft dated 2026-07-20
Proposition supported
Would let the source state tax income from automated digital services, capped at a percentage of the gross amount underlying payments.
Limitations
Same unresolved "[ ] per cent" cap as Article 5. Does not apply where payments qualify as royalties (Art. 3(1)(h)) or insurance premiums (Art. 7).
Notes
Article 6(4)'s list of covered services (online advertising, user data, online intermediation platforms, digital content, cloud computing) closely parallels Uganda's own Income Tax Act s.86(3).
Source
Co-Lead's Draft Protocol I, read directly from the source PDF
Accessed
2026-09-30
Instrument
Draft Protocol II to the UN Framework Convention -- Prevention and Resolution of Tax Disputes
Jurisdiction
International (UN)
Effective / draft date
Draft dated 2026-07-20
Proposition supported
Would establish mechanisms to prevent and resolve tax disputes between States Parties.
Limitations
At an earlier drafting stage than Protocol I -- article numbers themselves are bracketed placeholders (e.g. "Article [II.1]", "Article [III.2]") rather than settled numbering.
Source
Co-Leads' Draft Protocol II, read directly from the source PDF
Accessed
2026-09-30
Source register
Raw JSON ↓7 documents, each read directly
Every data set and document cited in the issue, in the order of priority this publication follows: Uganda law, then URA, then MoFPED, then UBOS/BOU, then the UN, then OECD/IMF/World Bank/ATAF/ICTD, then academic and secondary sources.
Organisation
Ministry of Finance, Planning and Economic Development (Uganda)
Document type
Government fiscal report (PDF)
Period covered
August 2026
Data type
Fiscal outturn vs. programme (revenue, taxes, expenditure, deficit)
Page / section
Table 5 -- Summary Table of Fiscal Operations, and accompanying body text
Supports
The August fiscal number, the tax-mix shortfall breakdown
Limitations
Figures are marked preliminary by MoFPED. Trade-tax sub-components are named qualitatively but not individually itemised by value.
Notes
Extracted directly from the published PDF (pdftotext, -layout), not a secondary summary.
Locator
mepd.finance.go.ug/documents/POE/2026/POE-2026-08-AUG.pdf
Accessed
2026-09-29
Organisation
Parliament of Uganda / Uganda Legal Information Institute
Document type
Consolidated legislation
Period covered
n/a
Data type
Statute text
Page / section
ss.82, 84, 86, 138; Schedule 4 Part V
Supports
The Ugandan rulebook section; the transaction simulator's domestic-law side
Limitations
Read directly from the consolidated statute text; no specific tax treaty was checked for an override on any real transaction.
Notes
ulii.org's own HTML pages return 403 to automated fetches; the underlying PDF is directly fetchable.
Locator
ulii.org (media.ulii.org consolidated PDF, via Laws.Africa)
Accessed
2026-09-29
Organisation
United Nations
Document type
Video/meeting record
Period covered
3-13 August 2026
Data type
Process/session timeline
Page / section
n/a
Supports
Confirms the Fifth Session dates and venue
Limitations
Official session transcripts (as opposed to meeting records) were not read for this issue; no delegation-specific interventions are attributed here.
Locator
webtv.un.org
Accessed
2026-09-29
Organisation
UN Department of Economic and Social Affairs, Financing for Sustainable Development Office
Document type
Institutional process page
Period covered
2025-2027 negotiation timeline
Data type
Process/timeline
Page / section
n/a
Supports
The negotiation timeline (2024/25 architecture, Fifth Session, texts intended for 2027)
Locator
financing.desa.un.org/unfcitc
Accessed
2026-09-29
Organisation
United Nations Intergovernmental Negotiating Committee
Document type
Negotiating text (PDF)
Period covered
n/a
Data type
Draft treaty text
Page / section
28 articles across Parts I-III (read in full)
Supports
The UN rulebook section; the protocol register
Limitations
One article (Art. 11) is bracketed/contested in the source text itself; this issue reports that status rather than resolving it.
Notes
Read directly, article by article, via pdftotext.
Locator
A/AC.298/CRP.32 (UN document symbol; PDF supplied directly, not fetched from a public URL)
Accessed
2026-09-30
Organisation
United Nations Intergovernmental Negotiating Committee
Document type
Negotiating text (PDF)
Period covered
n/a
Data type
Draft treaty text
Page / section
22 articles (read in full); Articles 5 and 6 quoted directly
Supports
The transaction simulator; the headline "rate left blank" finding
Limitations
This is the co-leads' own draft, not an agreed committee text -- it can change materially before any adoption.
Notes
Read directly, article by article, via pdftotext.
Locator
A/AC.298/CRP.33 (UN document symbol; PDF supplied directly)
Accessed
2026-09-30
Organisation
United Nations Intergovernmental Negotiating Committee
Document type
Negotiating text (PDF)
Period covered
n/a
Data type
Draft treaty text
Page / section
Six chapters (read in full)
Supports
The protocol register's note on Protocol II's earlier drafting stage
Limitations
Article numbers are themselves bracketed placeholders in this draft.
Notes
Read directly via pdftotext.
Locator
A/AC.298/CRP.34 (UN document symbol; PDF supplied directly)
Accessed
2026-09-30
Calculation register
Raw JSON ↓6 derived numbers, each reproducible
Every number in the issue that isn't a direct quote from a source is a calculation from one, shown here with its exact inputs and formula, including where our arithmetic on MoFPED's own rounded table differs from MoFPED's own stated total by a rounding cent.
Input source
MOFPED-POE-2026-08, Table 5
Input variables
{"tax_programme_ugx_bn":2975.86,"tax_outturn_ugx_bn":2663.21}
Rounding
2 decimal places, matching the source table
Calculated
2026-09-29
Analyst
TaxIntellilytics Stories
Notes
MoFPED's own body text states the shortfall as UGX 312.64bn -- a UGX 0.01bn difference from arithmetic on the table's own rounded figures, most likely because the underlying unrounded figures differ slightly from their 2-decimal display. This issue uses MoFPED's stated 312.64bn in prose and shows 312.65bn only where it is the direct arithmetic result of the displayed target/outturn.
Input source
MOFPED-POE-2026-08, Table 5
Input variables
{"tax_outturn_ugx_bn":2663.21,"tax_programme_ugx_bn":2975.86}
Rounding
1 decimal place
Calculated
2026-09-29
Analyst
TaxIntellilytics Stories
Notes
Matches MoFPED's own stated 89.5%.
Input source
MOFPED-POE-2026-08, Table 5
Input variables
{"domestic_revenue_outturn_ugx_bn":2872.47,"domestic_revenue_programme_ugx_bn":3238.15}
Rounding
1 decimal place -> 88.7%
Calculated
2026-09-29
Analyst
TaxIntellilytics Stories
Notes
Matches MoFPED's own stated 88.7%. Shortfall (3238.15 - 2872.47 = 365.68) also matches the source exactly.
Input source
MOFPED-POE-2026-08, Table 5
Input variables
{"total_revenue_outturn_ugx_bn":2895.82,"total_revenue_programme_ugx_bn":3299.1}
Rounding
1 decimal place -> 87.8%
Calculated
2026-09-29
Analyst
TaxIntellilytics Stories
Notes
Matches MoFPED's own stated 87.8%. Arithmetic deviation (3299.10 - 2895.82 = 403.28) differs from MoFPED's own stated -403.29 by UGX 0.01bn -- the same rounding pattern as CALC-001.
Input source
MOFPED-POE-2026-08, Table 5
Input variables
{"net_borrowing_outturn_ugx_bn":-708.85,"net_borrowing_programme_ugx_bn":-257.62}
Rounding
2 decimal places
Calculated
2026-09-29
Analyst
TaxIntellilytics Stories
Notes
The actual deficit ran UGX 451.23bn larger than planned.
Input source
MOFPED-POE-2026-08, body text and Table 5
Input variables
{"indirect_shortfall_ugx_bn":-170.39,"direct_shortfall_ugx_bn":-108.43,"trade_shortfall_ugx_bn":-49.36,"total_tax_shortfall_ugx_bn":-312.64}
Rounding
2 decimal places
Calculated
2026-09-30
Analyst
TaxIntellilytics Stories
Notes
MoFPED's own body text presents these three figures as the shortfall 'reflected across all major tax handles', but they sum to UGX 328.18bn -- UGX 15.54bn more than the UGX 312.64bn total tax shortfall the same report states. Table 5 has no category-level breakdown row for Indirect/Direct/International Trade taxes to check this against. Not established from public evidence whether this is a rounding effect across multiple report tiers, an incomplete category list, or something else -- reported as an open discrepancy, not resolved here.