Bestin Limited v Uganda Revenue Authority (TAT Application 230 of 2022)
Bestin Limited v Uganda Revenue Authority (TAT Application 230 of 2022) [2023] UGTAT 11 (29 June 2023)
The Tribunal found that the applicant entered into the agreement for the purchase of the business asset before the enactment of S.118B(2) of the Income Tax Act, with the majority of the consideration paid before the law came into force. The subsequent payments made after the commencement of the amendment were installments fulfilling an already completed transaction. The law did not expressly provide for its retrospective application to transactions concluded before its commencement, nor did it clarify the treatment of post-commencement installment payments for pre-commencement purchases. The…
Source excerpt
- Withholding Tax
- Retrospective Application
- Income Tax Amendment
- Business Asset Purchase
- Statutory Interpretation