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Tax Law [2024] UGCommC 301

Allied Beverages Company Limited v Commissioner Uganda Revenue Authority

Allied Beverages Company Limited v Commissioner Uganda Revenue Authority (Civil Appeal 39 of 2022) [2024] UGCommC 301 (18 September 2024)

The court held that the determining factor for VAT liability on cross-border services is the location where the services are finally consumed or used, not where they are performed. The VAT Act and Regulations, when read holistically, provide that services exported from Uganda and consumed outside Uganda qualify for zero-rating. The Service Agreement between the Appellant and TCCEC establishes that the consumer of the services is TCCEC, located in the USA, and the services are used for its business purposes outside Uganda. The court found that the Tribunal erred by focusing solely on the place…

  • Vat Export Services
  • Destination Principle
  • Statutory Interpretation
  • Cross Border Transactions
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Uganda decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.