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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...

Stanbic-URA Transfer-Pricing Dispute: What Finance Teams Should Learn While the Case Is Pending

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...

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...

Uganda FY2026/27 Budget: Tax Changes and What Finance Teams Should Do

Uganda's Financial Year 2026/27 Budget is more useful to a finance team when it is read in two layers: first as a statement of Government policy and spending priorities, and second as a set of tax and compliance changes that must be implemented in day-to-day systems, payroll, invoicing and reporting. The Budget Speech was delivered to Parliament on 11 June 2026. The final resource envelope is approximately UGX 84.39 trillion , including domestic revenues of about UGX 45.96 trillion, of which roughly UGX 40.16 trillion is tax revenue. The Government's stated development priorities continue to centre on agro-industrialisation, tourism, mineral-based industrial development, and science, technology and innovation. FGL review: September 2026. This article reflects the enacted and operational position reviewed after the Budget Speech, rather than treating every proposal announced in June as automatically final law. The Budget Speech Is Not the Same Thing as the Final Tax Law ...

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...

VAT Registration in Uganda: Threshold, EFRIS and What Businesses Should Know

Jurisdiction: Uganda · Topic: VAT registration and EFRIS · FGL review: September 2026 Not every business in Uganda is automatically required to register for VAT. The key starting point is whether the person is making taxable supplies and whether the statutory registration threshold has been met or is expected to be met. VAT registration and EFRIS are related, but they are not the same thing. VAT is a tax regime. EFRIS is an electronic invoicing and receipting system used by URA for transaction reporting and compliance. What is VAT in Uganda? Value Added Tax is an indirect tax charged on taxable supplies made by taxable persons, on taxable imports of goods and on imported services that are not exempt. Uganda's standard VAT rate is generally 18%, while some supplies are zero-rated at 0% and others are exempt under the VAT Act. Who must register for VAT? Under the current VAT Act and URA guidance, the annual registration threshold is UGX 300 million of taxable s...