FGL · Uganda Tax · Full Case Analysis Written by Ivan Lwanga · Finance & Governance Lab Jurisdiction Uganda Decision 31 October 2023 Case TAT Application 27 of 2022 Period Audit: July 2015 to June 2019 FGL focus Long-term contracts; estimated profits; comparator evidence; withholding tax Review date 31 October 2026 TAT application allowed; later-status limitation The Tribunal rejected the corporate-tax assessment and the WHT assessed under section 119. An official 2024 cause list identifies a civil appeal between the same parties; its connection to this ruling and final disposition were not established. [2] The Tribunal accepted URA's power to estimate income from long-term contracts, but rejected the unsupported margin used to calculate the assessment. A separate withholding-tax finding also turned on the provision actually relied on. The decision and its limits On 31 October 2023, Uganda's Tax Appeals Tribunal set aside a corporate-tax assessment of UGX 7,287,...

Uganda's Intergovernmental Fiscal Transfers Program, commonly known as UgIFT, offers a useful case study in a recurring governance problem: an organisation can mobilise funding, build assets, implement systems and report high levels of expenditure — yet still struggle to convert those inputs into the intended service outcomes. UgIFT was established as a Government of Uganda programme, supported by World Bank financing, to strengthen the adequacy, equity and effectiveness of financing for local government services. Over time, its scope covered education, health, water and environment, micro-scale irrigation, and services in refugee-hosting communities. The programme also produced measurable gains. The Auditor General's 2024 evaluation of the education component found that fiscal transfers to local governments had become more adequate and more equitably distributed, while the establishment of seed secondary schools expanded access to education. Enrolmen...

 From 1 July 2026, Uganda’s VAT withholding rules changed in an important way. URA has recently stated that, effective 1 July 2026, a designated VAT withholding agent is not required to withhold VAT on payments to a supplier who issues an EFRIS invoice or receipt. This follows the 2026 VAT amendment, which excludes VAT withholding where a designated person pays for taxable supplies and is issued an e-invoice or e-receipt. That sounds simple. But a practical question has now emerged: What happens to invoices that were issued before 1 July 2026 but are being reviewed, paid, or followed up after that date? The answer should not be reduced to one sentence. The safer approach is to separate three things: the invoice date, the payment date, and the existence of a valid EFRIS invoice or receipt. Under the old VAT withholding regime, designated VAT withholding agents were required to withhold VAT when making payment for taxable supplies, unless an exemption applied. Therefore, where p...