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,...

 From 1 July 2026, Uganda’s VAT withholding rules changed in an important way. URA has recently stated that, effective 1 July 2026, a designated VAT withholding agent is not required to withhold VAT on payments to a supplier who issues an EFRIS invoice or receipt. This follows the 2026 VAT amendment, which excludes VAT withholding where a designated person pays for taxable supplies and is issued an e-invoice or e-receipt. That sounds simple. But a practical question has now emerged: What happens to invoices that were issued before 1 July 2026 but are being reviewed, paid, or followed up after that date? The answer should not be reduced to one sentence. The safer approach is to separate three things: the invoice date, the payment date, and the existence of a valid EFRIS invoice or receipt. Under the old VAT withholding regime, designated VAT withholding agents were required to withhold VAT when making payment for taxable supplies, unless an exemption applied. Therefore, where p...

A taxpayer can pay the exact amount agreed as principal tax and still discover years later that the tax ledger shows principal outstanding and interest continuing to accumulate. That problem sat at the centre of CARE International in Uganda v Uganda Revenue Authority , TAT Application No. 353 of 2025, decided by Uganda's Tax Appeals Tribunal on 7 September 2026. The ruling is important for finance and tax teams because it moves the discussion beyond whether tax was paid. It asks the next control question: how was the payment actually allocated on the taxpayer's ledger? FGL takeaway: Paying a tax assessment is not the final control. The payment must also be reconciled to the tax authority's ledger, including how the amount was split between principal tax, penal tax and interest. The dispute in brief CARE International in Uganda is a non-profit international organisation involved in humanitarian activities and emergency response. The underly...

On 7 September 2026, the Uganda Revenue Authority published the compliance risks that will receive particular attention under its Compliance Improvement Plan for the 2026/27 financial year. The notice lists 22 risk areas covering inventory, excise duty, exports, sales, expenses, payroll, withholding tax, EFRIS, Digital Tax Stamps and related-party transactions. The practical response is to review the links between your accounting records, tax returns and operational systems before URA asks for an explanation. Do not force every record to match. Identify genuine errors, correct them through the proper process, and document valid timing, classification or system differences. This article explains what URA has announced and sets out a practical readiness programme for finance teams, tax managers and business owners. It does not assume that every organisation will face an audit or that every variance represents unpaid tax. What URA Actually Announced URA says the FY 2026/27 ...

Uganda Revenue Authority has confirmed that the Income Tax (Amendment) Act, 2026 and the Excise Duty (Amendment) Act, 2026 were assented to with a commencement date of 1 July 2026 . URA has consequently advised taxpayers to review returns and declarations already filed for July 2026, August 2026 and subsequent periods and make any adjustments necessary to reflect the amended provisions. For finance and tax teams, the important issue is not merely that the law changed. It is that the commencement date reaches back to the beginning of the 2026/27 financial year, while some taxpayers may already have filed returns before the administrative systems and return templates were updated. That creates a practical compliance task: identify affected filings, determine whether they were prepared using the correct post-amendment rules, correct them where necessary and reconcile any resulting tax, payroll or credit consequences. Why the timing matters The legislative path helps expla...

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...

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...

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...