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Ernst & Young v URA: VAT on Imported Services and the UGX 3.48 Billion Assessment

Jurisdiction: Uganda · Decision: Commercial Court, Civil Appeal No. 26 of 2022 · Judgment date: 11 June 2026 · FGL review: September 2026 Uganda's Commercial Court has upheld a VAT assessment of UGX 3,482,492,210 against Ernst & Young Uganda in a dispute over services received from non-resident group entities and other foreign service providers. The decision is important because it gives businesses a current judicial example of how Uganda's imported-services VAT rules can apply to cross-border support, technology and professional-service arrangements. What the case was about In Ernst and Young v Uganda Revenue Authority , Civil Appeal No. 26 of 2022, the dispute concerned services obtained from entities outside Uganda, including members of the wider EY network and third-party foreign suppliers. URA treated the services as imported services and assessed VAT for the period January 2014 to June 2018. EY challenged the treatment, including arguments about where the s...

Reconciling ERP Sales, EFRIS, VAT and Income Tax Returns: A Practical Guide

Scope: Uganda · Topic: Revenue reconciliation across ERP, EFRIS, VAT and income tax · FGL review: September 2026 Sales should be explainable across every system a business uses, but they will not always be numerically identical. An ERP may record invoices and journals, EFRIS records fiscal documents, VAT follows statutory supply rules, financial statements apply accounting standards, and the income-tax return applies tax rules to annual business income. The control objective is therefore not to force all four numbers to match. It is to build a documented bridge that explains why they differ, whether each difference is valid, and what evidence supports it. Why the numbers can legitimately differ A difference can arise from timing, classification, system configuration or tax treatment. Common examples include advance billings, deferred income, unbilled revenue, credit notes, exempt or zero-rated supplies, manual journals, foreign-currency treatment, customer-contra...

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

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