A Ugandan commodities company challenged the Uganda Revenue Authority's application of the 30% EBITDA interest deductibility cap using gross rather than net interest expense. The company argued for a net interest approach based on GAAP and OECD BEPS Action 4 guidance. The Tax Appeals Tribunal dismissed the application in 2025, upholding URA's position that section 25(3) of the Income Tax Act unambiguously applies to gross interest expense ... Read more

An Australian engineering consultancy's Ugandan branch disputed the disallowance of head office cost allocations, overhead recharges, and regional office charges for 2011–2016. The Uganda Tax Appeals Tribunal found in favour of the tax authority in 2024, ruling that SMEC International failed to provide adequate documentation proving the services were actually rendered and satisfied the benefit test ... Read more

Allied Beverage Company Ltd. provided brand marketing services in Uganda to The Coca-Cola Export Corporation, a US-based entity. Uganda's tax authority assessed UGX 17.4 billion in VAT, arguing the services were locally consumed. The Tax Appeals Tribunal upheld the assessment, but Uganda's High Court overturned that decision in September 2024, ruling in favour of the taxpayer and referencing OECD VAT/GST Guidelines on cross-border services ... Read more

The Uganda Revenue Authority sought to pierce the corporate veils of five commonly owned and directed companies allegedly used to conceal assets and evade over UGX 20 billion in taxes. Profits from Ural truck sales were shifted offshore through a Dubai branch, with management fees and bonuses paid without withholding tax. The Uganda High Court ruled in favour of the tax authority in 2024, finding deliberate misuse of the corporate form to frustrate tax recovery ... Read more

A Ugandan tea out-grower challenged a transfer pricing assessment issued by the tax authority following an audit of its green leaf tea sales to associated company Kijura Tea Company Limited. The authority argued prices were understated and disallowed assessed losses, raising a tax assessment of over Shs. 544 million. The Tax Appeals Tribunal, in its March 2021 decision, ruled in favour of the taxpayer, finding the price adjustment did not conform with the law ... Read more

East African Breweries International Ltd, a Kenyan subsidiary marketing Ugandan products in foreign markets, faced a Ugandan income tax assessment of over Shs. 9.7 billion on the basis it was resident in Uganda. The Uganda Tax Appeals Tribunal ruled in the taxpayer's favour in 2020, finding the company was not a taxable person in Uganda and rejecting the tax authority's residency and transfer pricing arguments ... Read more