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Citation
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Judgment date
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| September 2025 |
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An ADR tax settlement is binding and precludes interim injunction where the tribunal lacks statutory jurisdiction to review it.
Tax law – ADR settlement agreements – binding and enforceable under ADR regulations (Regns 11–14); jurisdiction – appellate/review jurisdiction must be statutory; interim relief – requirements for interlocutory injunction (prima facie case, irreparable injury, balance of convenience).
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1 September 2025 |
| August 2025 |
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Carry forward losses are allowable deductions in computing Tax EBITDA under section 25; application dismissed with costs.
Tax law – Interest limitation – Section 25 (Tax EBITDA) – Whether carry forward (assessed) losses are "allowable deductions" for computing Tax EBITDA – Interaction of sections 15, 22 and 36 – Tax EBITDA is a tax concept linked to chargeable income.
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20 August 2025 |
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Tribunal set aside stamp-duty assessment made without verifying the actual employment and supplier agreements.
Stamp Duty — instruments — Item 5, Second Schedule — agreements (including employment and supply contracts) chargeable; duty attaches on execution; payer in absence of contrary agreement is person drawing/making/executing instrument; assessments must be based on verified documents — PAYE/withholding returns alone insufficient; burden of proof on taxpayer to show assessment incorrect; matter remitted for recomputation.
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18 August 2025 |
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Tribunal upheld the assessment, finding the shareholder’s loan was personal and disputed rental deductions were not deductible by the company.
Tax — administrative additional income tax assessment; disallowed rental expense claims; 75% expense capping; loan to shareholder versus company expense; separate legal personality (Salomon); burden to produce supporting documentation; application of Income Tax (Amendment) Act 2022 (timing).
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15 August 2025 |
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Whether the applicant may appeal an ADR Committee taxation decision to the Tax Appeals Tribunal and comply with time and 30% payment rules.
* Tax law – Tax Appeals Tribunal jurisdiction – Whether decisions of Uganda Revenue Authority’s ADR Committee are reviewable by the Tax Appeals Tribunal.
* Procedural law – Statutory time limits – Computation of appeal time following service of an objection decision or ADR decision.
* Tax procedure – Requirement to remit 30% of disputed tax before lodging an appeal with the Tribunal.
* ADR – Effect of ADR proceedings on the timelines for filing appeals to the Tax Appeals Tribunal.
* Precedent – Binding effect of High Court decisions on the Tribunal’s jurisdictional interpretation.
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12 August 2025 |
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WHT on interest paid by a bank to an exempt organisation is final tax under section 139(a).
Tax — Interpretation of Income Tax Act s.139(a) — Withholding tax on interest paid by financial institutions to exempt organisations — Final tax — Effect of exemption certificate — Sections 127, 139 and 21(1)(f).
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2 August 2025 |
| July 2025 |
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Whether the 30% EBITDA interest cap applies to gross or net interest — tribunal held it applies to gross interest.
Tax law – Interest limitation – Section 25(3) EBITDA 30% cap applies to deductible interest (gross interest incurred); GAAP and OECD BEPS Action 4 persuasive but not binding; statutory interpretation prevails where wording is clear; taxpayer bears burden of proof in tax assessments.
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30 July 2025 |
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Whether group life assurance premiums are deductible or excluded as life insurance under the Income Tax Act.
* Tax — Income Tax Act s.22(1) deduction — whether group life assurance premiums are deductible or excluded under s.22(3)(i).
* Tax — Definition of "life insurance business" (s.16(3)) — interpretation of coverage, duration and benefits.
* Mixed policies — where a single policy combines life and short‑term insurance elements, proportional allocation of premiums required.
* Remedy — assessment set aside and recomputation ordered; costs awarded.
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17 July 2025 |
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The applicant may claim initial allowance after converting previously commercial warehouses into industrial buildings first used in its business.
Tax — Income Tax Act, s.27A — Initial allowance for industrial buildings — Classification by primary use (manufacturing v warehousing) — 'Placed in service for the first time' means first use in the taxpayer's business — Prior ownership by another taxpayer does not bar new owner claim — Evidence: renovations, machinery imports, financial statements, KCCA/NEMA approvals.
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10 July 2025 |
| June 2025 |
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Income tax—capital gains—business asset—adventure in the nature of trade—sale of undeveloped land—registered tax profile not conclusive—no evidence of repeated land transactions—land held for nine years—no improvements prior to sale—personal asset—burden of proof—respondent failed to prove business use—assessment quashed—costs
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30 June 2025 |
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25 June 2025 |
| April 2025 |
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Tax law—VAT exemption—ferry supply contract—ferry held to be machinery—applicant engaged in logistics—contract not to be artificially split—tribunal found all exemption conditions met—VAT exemption granted—refund and costs
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30 April 2025 |
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20 April 2025 |
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11 April 2025 |
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1 April 2025 |
| March 2025 |
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31 March 2025 |
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21 March 2025 |
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7 March 2025 |
| February 2025 |
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28 February 2025 |
Tax law—VAT—imported services—statute of limitations—discovery of new information—willful neglect—tax assessments—burden of proof—taxpayer obligations—case dismissal—costs
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13 February 2025 |
| November 2024 |
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Taxation disputes—Vat assessment—serviced apartments—immovable property—active vs passive exploitation—added value—residential exemptions—ambiguity in tax law—statutory interpretation—burden of proof—judicial oversight—costs awarded
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4 November 2024 |
| October 2024 |
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31 October 2024 |
| August 2024 |
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23 August 2024 |
| July 2024 |
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5 July 2024 |
| December 2023 |
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22 December 2023 |
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22 December 2023 |
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22 December 2023 |
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21 December 2023 |
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20 December 2023 |
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20 December 2023 |
| November 2023 |
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30 November 2023 |
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28 November 2023 |
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24 November 2023 |
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23 November 2023 |
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22 November 2023 |
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14 November 2023 |
| October 2023 |
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31 October 2023 |
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31 October 2023 |
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24 October 2023 |
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24 October 2023 |
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23 October 2023 |
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13 October 2023 |
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13 October 2023 |
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6 October 2023 |
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5 October 2023 |
| September 2023 |
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29 September 2023 |
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29 September 2023 |
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28 September 2023 |
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28 September 2023 |
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14 September 2023 |
