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Tax Appeals Tribunal (Uganda)

The Tax Appeals Tribunal of Uganda (TAT) was established by an Act of Parliament in 1997. By enhancing this Act, parliament was fulfilling the requirement in Article 152 (3) of the Constitution 1995. Tax Appeals Tribunal opened its doors to the public in May 1999. The duty of Tax Appeals Tribunal of Uganda is to settle Tax Disputes between tax payers and the Uganda Revenue Authority (URA)

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NIC Building, 7/8th Floor
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https://www.tat.go.ug/
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3 judgments
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November 2011
Heritage Oil and Gas Limited v Uganda Revenue Authority (TAT Application No. 26 of 2010) [2011] UGTAT 8 (23 November 2011)
Disposal of PSA/J OA rights was taxable as an interest in immovable property or Uganda‑sourced business income; assessment upheld.
* Tax — Sale of PSA/JOA participating interest — whether disposal constitutes an interest in immovable property under domestic law and the Uganda–Mauritius DTAA (Article 6) — held taxable. * Tax procedure — Commissioner’s discretion to assess under S.92(8)/S.95(4) where no return filed — assessment upheld. * Deductions — exploration costs recoverable under PSA excluded from deduction (S.22(2)(c)); signature bonuses allowable in cost base (Part VI). * Onus of proof — taxpayer must prove assessment excessive (S.102). * Currency/formal defects — calculation in US$ and citation errors not fatal (S.98(3)).
 23 November 2011
Heritage Oil and Gas Limited v Uganda Revenue Authority (TAT Application No. 28 of 2010) [2011] UGTAT 6 (23 November 2011)
A settlement payment tied to the sale of Ugandan petroleum interests was taxable as income attributable to activities in Uganda; assessment upheld.
* Taxation – Sale of petroleum participating interest – Contingent/settlement payment as part of consideration – taxable as business profit attributable to activities in Uganda (S.79(s)). * Tax procedure – Commissioner’s discretion to assess under S.95 read with S.92(8) where no return filed and taxpayer about to cease activity. * Formal defects – Wrong statutory citation and assessment in foreign currency do not void assessment (S.98(3)); S.57’s currency requirement not fatal. * International law – Double Taxation Agreement considered alongside domestic source rules; substance over form in tax characterization.
 23 November 2011
Heritage Oil & Gas Ltd v Uganda Revenue Authority (Application No. TAT 26 of 2010) [2011] UGTAT 5 (23 November 2011)
Sale of petroleum contract interests taxable as disposal of immovable‑property interest; URA assessment upheld.
Taxation — Petroleum PSAs/JOA — Sale of participating interest — bundle of rights (cost recovery, profit oil, usufruct/accessory rights) — interest in immovable property; source rules S.79(g)/S.79(s); Double Taxation Agreement; Commissioner’s discretion to assess under S.92(8)/S.95(4); recoverable exploration costs excluded by S.22(2)(c); assessment upheld.
 23 November 2011