Uganda Case Law

Dr. Amos Nzeyi v Uganda Revenue Authority

Dr. Amos Nzeyi v Uganda Revenue Authority (Tax Application 5 of 2024) [2025] UGTAT 11 (30 June 2025)

Court

Tax Appeals Tribunal (Uganda)

Case number

Tax Application 5 of 2024

Judges

Crystal Kabajwara -Chairperson, Ali, Panel Member, Katwe

The Tribunal found that the Applicant held the land for nine years as a personal investment, with no evidence of repeated transactions, business use, or modifications to the asset indicative of trade. The Applicant's tax returns consistently declared only dividend and rental income, and there was no history of land trading. The Respondent's reliance on the Applicant's tax profile was insufficient to establish business activity, as registration codes do not constitute factual proof. The Tribunal concluded that the land was not a business asset within the meaning of the Income Tax Act, and the…

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• Income Tax Assessment
• Business Asset Definition
• Capital Gains Exemption
• Taxable Income
• Burden Of Proof
• Taxpayer Registration Evidence

Luwaluwa Investments Limited v Uganda Revenue Authority (Application 39 of 2021)

Luwaluwa Investments Limited v Uganda Revenue Authority (Application 39 of 2021) [2022] UGTAT 30 (22 September 2022)

Court

Tax Appeals Tribunal (Uganda)

Case number

Application 39 of 2021

Judges

Mugenyi, Chairperson, Ali, Panel Member, Katwe

The majority of the Tribunal held that Section 118B(2) of the Income Tax Act is clear and unambiguous in requiring a resident person who purchases a business asset to withhold tax at the prescribed rate, regardless of whether the seller is the owner or a financial institution acting as a mortgagee. The Tribunal found that the property in question, Afrique Suites, qualified as a business asset because it was used as a hotel, and the applicant, as purchaser, was obligated to withhold tax. The Tribunal rejected the applicant's arguments regarding statutory exemptions and ambiguity, holding that…

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• Withholding Tax
• Mortgaged Property Sale
• Business Asset Definition
• Statutory Interpretation
• Tax Exemptions

The Registered Trustees of Freemansons Hall v Uganda Revenue Authority (Application 51 of 2019)

The Registered Trustees of Freemansons Hall v Uganda Revenue Authority (Application 51 of 2019) [2021] UGTAT 28 (29 July 2021)

Court

Tax Appeals Tribunal (Uganda)

Case number

Application 51 of 2019

Judges

Mugenyi, Chairperson, Mugerwa, Panel Member, Katwe

The Tax Appeals Tribunal held that URA’s assessment was invalid because it failed to revoke a binding private ruling before taxing the sale, and it also miscomputed the gain.

• Capital Gains Tax
• Private Ruling Binding Effect
• Tax Assessment Computation
• Business Asset Definition
• Tax Exemption
• Procedural Requirements

Registered Trustees of Free Masons v Uganda Revenue Authority (Application No. TAT 51 of 2019)

Registered Trustees of Free Masons v Uganda Revenue Authority (Application No. TAT 51 of 2019) [2021] UGTAT 20 (29 July 2021)

Court

Tax Appeals Tribunal (Uganda)

Case number

Application No. TAT 51 of 2019

Judges

Katwe, Panel Member, Mugerwa, Mugenyi, Chairperson

The Tribunal held that the Commissioner was bound by an unrevoked private ruling and that the capital gains assessment was wrongly computed.

• Capital Gains Tax
• Private Ruling Binding Effect
• Tax Assessment Computation
• Business Asset Definition
• Tax Exemption
• Procedural Objection