Stanbic-URA Transfer-Pricing Dispute: What Finance Teams Should Learn While the Case Is Pending

Jurisdiction: Uganda · Topic: Transfer pricing and tax dispute management · Status: Pending before the Tax Appeals Tribunal at the time of this FGL review · FGL review: 21 September 2026

Stanbic Bank Uganda Limited and Stanbic Uganda Holdings Limited are contesting a major transfer-pricing assessment by the Uganda Revenue Authority (URA). Public reporting places the working dispute figure at approximately UGX 117.8 billion, and the Tax Appeals Tribunal listed TAT Application No. 170 of 2025 for conferencing in June 2026.

This article does not attempt to decide who is right. The dispute is still being litigated. Instead, it uses the publicly available record to explain what finance teams can learn about related-party charges, evidence, tax governance and the management of unresolved assessments.

What the dispute is about

The dispute arises from URA's review of related-party transactions involving Stanbic's Ugandan operations and entities within the wider Standard Bank Group. Public reporting identifies franchise or management charges, technology and support costs, cost allocations and other intra-group arrangements among the areas under scrutiny.

The core transfer-pricing question is whether the amounts charged between related entities were consistent with the arm's-length principle: in broad terms, whether the pricing and allocation would be supportable if comparable independent parties had entered into the transaction.

That is not answered by the existence of an invoice alone. A taxpayer normally needs to demonstrate the commercial substance of the service, who benefited, how the charge was calculated, why the allocation key was appropriate and how the pricing was supported.

The assessment has changed as the audit progressed

Stanbic Uganda Holdings' published financial reporting shows that the transfer-pricing audit began in 2017 for the 2012-2016 years of assessment and was later extended to 2017-2019. Its 2024 annual report disclosed a February 2025 assessment with total potential principal tax of UGX 122.6 billion, followed by a March 2025 audit report showing UGX 133.7 billion before interest and penalties.

Subsequent public reporting has referred to approximately UGX 117.8 billion as the working figure associated with the dispute before the Tribunal. The movement in these amounts is itself a useful reminder: an assessment can change through audit findings, objections, revised computations and the identification of disputed versus undisputed items.

Why related-party service charges need more than an agreement

For management, technology, brand, regional-support and shared-service charges, an intercompany agreement is necessary evidence but rarely the whole file. A strong support pack should also show:

• the service actually provided;
• the Ugandan entity that received or benefited from it;
• the basis on which the cost pool was created;
• the allocation key used and why it reflects expected benefit;
• whether shareholder or parent-only costs were excluded;
• whether the same cost was recovered elsewhere;
• the pricing method and comparables used where relevant; and
• contemporaneous evidence that existed before a tax dispute arose.

The practical control is to make the transfer-pricing file traceable to the accounting ledger. A reviewer should be able to move from the intercompany invoice to the contract, service evidence, allocation workbook, general-ledger posting, tax treatment and payment.

The URA banking relationship is a separate issue from the tax case

In June 2026, public reporting reproduced a URA letter stating that the Authority intended to transfer its accounts away from Stanbic by the end of the calendar year following a review of matters including tax compliance and transparency. That commercial or institutional decision should not be confused with a final judicial finding on the underlying tax assessment.

An unresolved tax dispute is not the same thing as a final determination that the taxpayer underpaid tax. Equally, a taxpayer's decision to challenge an assessment does not remove the need to manage regulatory, stakeholder and disclosure consequences while the dispute remains open.

What finance teams should learn from a pending dispute

The strongest lesson is not that every intra-group charge is risky. It is that related-party costs are vulnerable when finance, tax, legal and operational evidence are assembled only after URA asks questions.

• Document the benefit when the service is received. Do not wait for an audit to explain why the Ugandan entity needed the service.
• Reconcile the transfer-pricing file to the ledger. Every material charge should be traceable to the accounts and tax computation.
• Challenge allocation keys. Headcount, revenue, assets, transaction volume and other drivers should be used because they fit the service, not because they are convenient.
• Screen for duplication. Similar invoices, franchise fees, project charges and local vendor costs should be reviewed for overlap.
• Separate parent/shareholder activity from operating services. Not every group-level activity necessarily creates a deductible local service charge.
• Maintain an audit trail across years. Long-running reviews are much harder when agreements, emails, allocation schedules and system data cannot be reconstructed.

Do not treat a pending case as settled law

As at this FGL review, the Stanbic transfer-pricing dispute remains a pending matter. FGL has not identified a published final Tribunal ruling on TAT Application No. 170 of 2025. Any article that presents URA's allegations, Stanbic's defence or likely commercial consequences should therefore distinguish clearly between allegation, taxpayer position, public disclosure and final adjudication.

This matters for readers and for search quality. A pending dispute should not be written as though one side has already won.

How this connects to the wider FGL tax library

The evidence discipline in this dispute connects directly to FGL's analysis of Medisell v URA, where the quality of tax evidence and audit methodology is central. Finance teams should also review the ERP, VAT and income-tax reconciliation guide for a practical example of how system records should be bridged before a tax review.

More Uganda-specific tax analysis is organised in the Uganda Tax knowledge desk.

Sources and status references

• Tax Appeals Tribunal cause list for 8-12 June 2026, listing Stanbic Bank Uganda Limited v URA, Case No. 170/2025, for conferencing.
• Stanbic Uganda Holdings investor reporting page, including the 2025 annual report and subsequent reporting.
• Stanbic Uganda Holdings 2024 Annual Report, which disclosed the transfer-pricing audit history and 2025 assessment amounts.
• Daily Monitor reporting on the Stanbic transfer-pricing dispute.
• CEO East Africa reporting on URA's June 2026 account-transfer letter and the pending dispute.

FGL note: This is a developing dispute. The article should be reviewed again when the Tax Appeals Tribunal publishes a ruling or when either party makes a material new public disclosure.