Jurisdiction: Uganda · Decision: Tax Appeals Tribunal · Neutral citation: [2017] UGTAT 121 · Decision date: 4 August 2017 · FGL review: September 2026 A royalty or licence fee can look like an ordinary commercial expense in the accounts. For customs purposes, however, the question is different: must that payment be added to the value of imported goods and therefore increase the customs duties and import taxes calculated on those goods? Bata Shoe Co. Ltd v Uganda Revenue Authority is an important Ugandan decision on that question. The Tribunal accepted that the trademark royalties were connected to the Bata-branded footwear, but it still vacated the assessment because URA had not established the separate requirement that payment of the royalties was a condition of sale of the imported goods. What triggered the dispute Bata Shoe Company Uganda sold and distributed footwear imported from countries including Kenya, Singapore and China under the Bata...

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...

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...

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...

Jurisdiction: Uganda · Topic: Transfer pricing and tax dispute management · Status: Pending before the Tax Appeals Tribunal at the time of this FGL review · FGL review: 21 September 2026 Stanbic Bank Uganda Limited and Stanbic Uganda Holdings Limited are contesting a major transfer-pricing assessment by the Uganda Revenue Authority (URA). Public reporting places the working dispute figure at approximately UGX 117.8 billion , and the Tax Appeals Tribunal listed TAT Application No. 170 of 2025 for conferencing in June 2026. This article does not attempt to decide who is right. The dispute is still being litigated. Instead, it uses the publicly available record to explain what finance teams can learn about related-party charges, evidence, tax governance and the management of unresolved assessments. What the dispute is about The dispute arises from URA's review of related-party transactions involving Stanbic's Ugandan operations and entities within the wider...

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...