Uganda Case Law

Kampala Hospitality Development Limited v Uganda Revenue Authority (Taxation Application 69 of 2023)

Kampala Hospitality Development Limited v Uganda Revenue Authority (Taxation Application 69 of 2023) [2025] UGTAT 1 (13 February 2025)

Court

Tax Appeals Tribunal (Uganda)

Case number

Taxation Application 69 of 2023

Judges

Crystal Kabajwara -Chairperson, Ali, Panel Member, Katwe

The Tribunal held that VAT assessments outside the three-year period were not barred where the applicant’s failure to account for VAT on imported services amounted to willful neglect.

• Vat Assessment
• Statute Of Limitations
• Willful Neglect
• Imported Services
• Withholding Tax
• Administrative Assessment

Uganda Electricity Transmission Company Limited (UETCL) v Uganda Revenue Authority (Taxation Application No. 46 of 2018)

Uganda Electricity Transmission Company Limited (UETCL) v Uganda Revenue Authority (Taxation Application No. 46 of 2018) [2022] UGTAT 8 (1 February 2022)

Court

Tax Appeals Tribunal (Uganda)

Case number

Taxation Application No. 46 of 2018

Judges

Akabway, Panel Member, Mugerwa, Mugenyi, Chairperson

The Tribunal held that design services in EPC transmission-line contracts were incidental to an exempt supply, but upheld withholding tax and denied input VAT credit.

• Vat Liability
• Withholding Tax
• Imported Services
• Input Vat Credit
• Aid Funded Projects
• Vat-liability

Uganda Revenue Authority v COWI A/S

Uganda Revenue Authority v COWI A/S (Civil Appeal 34 of 2020) [2021] UGCommC 187 (18 October 2021)

Court

Commercial Court of Uganda

Case number

Civil Appeal 34 of 2020

Judge

Stephen Mubiru, J

The High Court held that services supplied by COWI A/S’s Denmark head office to its Ugandan branch were imported services subject to VAT, and allowed URA’s appeal.

• Value Added Tax
• Imported Services
• Branch Vs Head Office
• Corporate Veil Piercing
• Tax Refunds
• Statutory Interpretation

Uganda Revenue Authority v COWI A/S

Uganda Revenue Authority v COWI A/S (Civil Appeal No. 34 of 2020) [2021] UGCA 134 (18 October 2021)

Court

Court of Appeal of Uganda

Case number

Civil Appeal No. 34 of 2020

Judge

Stephen Mubiru, J

The court held that Regulation 13 (3) (a) of The Value Added Tax (Amendment) Regulations, 2011, lawfully treats a branch in Uganda and its overseas head office as separate taxable persons for VAT purposes, even though they are part of the same legal entity. This regulatory approach is consistent with the principle of tax neutrality and the destination principle underlying VAT, ensuring parity between domestic and imported services. The services rendered by the head office in Denmark to the Ugandan branch, for which costs were allocated, constituted imported services consumed in Uganda and wer…

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• Value Added Tax
• Imported Services
• Branch Office Taxation
• Corporate Veil Piercing
• Tax Refunds

Apollo Hotel Corporation v Uganda Revenue Authority (Application No. TAT 68 of 2018)

Apollo Hotel Corporation v Uganda Revenue Authority (Application No. TAT 68 of 2018) [2021] UGTAT 4 (27 August 2021)

Court

Tax Appeals Tribunal (Uganda)

Case number

Application No. TAT 68 of 2018

Judges

Katwe, Panel Member, Ali, Mugenyi, Chairperson

The tribunal found that the rights granted to the applicant under the international license agreement, including the use of the Sheraton brand and system (which encompasses the centralized reservation system), constitute services rather than goods. These services were supplied by Sheraton International Inc., a foreign entity, for use and consumption in Uganda, thereby qualifying as imported services under the VAT Act. Applying the destination principle, VAT is chargeable on such imported services. However, the tribunal determined that the principal service was the right to operate the hotel u…

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• Value Added Tax
• Imported Services
• Franchise Agreements
• Intellectual Property Rights