The Registered Trustees of Mengo Hospital v Uganda Revenue Authority (Application 44 of 2022) [2023] UGTAT 64 (28 September 2023)
Court
Tax Appeals Tribunal (Uganda)
Case number
Application 44 of 2022
Judges
Mugenyi, Chairperson, Mugerwa, Panel Member, Ali
The Tribunal partly allowed Mengo Hospital’s tax exemption application, granting exemption for 1 July 2016 to 30 June 2018 but not for later periods.
The Tribunal found that the applicant's trust deed does not establish it as a religious or charitable institution of public character as required under S. 2(bb)(B) of the Income Tax Act. The objectives of the applicant are limited to property management and do not include religious or charitable purposes. Charitable activities conducted by related entities or as part of corporate social responsibility do not confer charitable status on the applicant itself. Membership restrictions and lack of public accessibility further negate public character. The Tribunal held that rental income from the h…