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Showing posts with the label Cross-Border Services

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...

VAT on Imported Services in Uganda: Reverse Charge, Input Tax and WHT

Jurisdiction: Uganda · Topic: VAT on imported services · FGL review: September 2026 Ugandan businesses increasingly buy software, cloud hosting, consulting, legal support, advertising, technical assistance and group services from suppliers outside Uganda. A foreign supplier may not charge Ugandan VAT on its invoice, but that does not necessarily mean the transaction is outside Uganda's VAT system. What is an imported service? Uganda's VAT framework imposes VAT on a supply of imported services other than an exempt service, with the tax payable by the person receiving the supply. In practical terms, this can capture services supplied by a non-resident provider and utilised or consumed by a recipient in Uganda. The 2026 decisions in Ernst and Young v URA and Sogea Satom v URA reinforce the importance of looking at the substance of the service and where the benefit is received, rather than assuming that an offshore contract or remote delivery keeps the transactio...