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Showing posts with the label Tax Assessments

Medisell v URA: Accounting Differences, Tax Evidence and the Limits of Audit Methodology

Jurisdiction: Uganda · Decision: Tax Appeals Tribunal, Applications Nos. 51 & 72 of 2023 · Ruling date: 4 August 2026 · FGL review: September 2026 Medisell Uganda Limited v Uganda Revenue Authority is a useful finance case because it shows the difference between an accounting or reconciliation variance and a legally taxable transaction. The dispute covered corporate income tax, VAT and PAYE for periods between 2017 and 2020 and arose from URA audit work that compared accounting records with customs, stock and payroll information. The Tribunal set aside a corporate income tax assessment of UGX 996,746,527 and VAT of UGX 9,630,468 that had been derived from cost-of-sales variances. It nevertheless upheld VAT of UGX 1,465,020 on a disposal to Medisell Rwanda where the taxpayer did not provide sufficient evidence that the goods had actually been exported. The PAYE findings were also mixed, depending on the evidence supporting the relevant payments and motor...

Bujagali Energy v URA: Late Assessments, Foreign Currency and Capital Allowances

Jurisdiction: Uganda · Decision: Tax Appeals Tribunal, Application No. 4 of 2024 · Ruling date: 30 April 2026 · FGL review: September 2026 Bujagali Energy Limited v Uganda Revenue Authority is a useful case for finance teams because it brings several difficult tax-control questions into one dispute: when an old tax period can be reopened, how foreign-currency expenditure should be translated for tax purposes, how capital project costs should be classified, and how documentary evidence affects withholding-tax positions. The Tribunal ultimately dismissed Bujagali Energy Limited's application and upheld a revised assessment of UGX 155,618,956,094, comprising income tax of UGX 155,320,573,662 and withholding tax of UGX 298,382,432. Why the case matters Large projects often produce tax positions that remain relevant long after the original transaction. Construction costs may be incurred in several currencies and across several years. Assets may be commissione...

Ericsson AB v URA: How to Reconcile VAT and Income Tax Sales Variances

Jurisdiction: Uganda · Decision: Tax Appeals Tribunal, Application No. 60 of 2020 · Ruling date: 29 May 2026 · FGL review: September 2026 Differences between sales reported in VAT returns, income-tax records and financial statements can trigger serious tax questions. But a variance is not, by itself, a complete tax analysis. Ericsson AB v Uganda Revenue Authority is a useful reminder that the underlying transactions, evidence and VAT computation still have to be examined. The dispute URA conducted a returns examination covering 2013 to 2017 and issued additional income-tax and VAT assessments against Ericsson AB's Ugandan branch. One of the central issues was a difference between sales reported for VAT purposes and revenue reflected in income-tax reporting. The Tribunal did not treat the existence of a numerical difference as the end of the analysis. It considered how the remaining unreconciled variance should be treated for VAT, together with interest...