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PAC SPA v URA — Estimated profits, evidence and withholding tax

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,...