Cowi A/S v Uganda Revenue Authority (Application No. TAT 4 of 2019)
Cowi A/S v Uganda Revenue Authority (Application No. TAT 4 of 2019) [2020] UGTAT 21 (22 May 2020)
The Tribunal held that the VAT Act does not recognize a branch as a separate legal person for VAT purposes, and the supply of services by employees of the head office to the branch does not constitute an import of services under the Act. Regulation 13(3) of the VAT Regulations, which treats the head office and branch as separate persons for VAT on imported services, cannot override the parent Act and does not apply where the service provider and recipient are the same legal entity. The Tribunal found that the costs allocated by the head office to the branch are not subject to VAT as imported…
Source excerpt
- Vat Imported Services
- Branch Vs Head Office Taxation
- Subsidiary Legislation Ultra Vires
- Double Taxation Agreement
- Definition Of Person Vat Act