Uganda Case Law

Absa Bank Uganda Limited v Uganda Revenue Authority (TAT Application 57 of 2021)

Absa Bank Uganda Limited v Uganda Revenue Authority (TAT Application 57 of 2021) [2023] UGTAT 8 (22 November 2023)

Court

Tax Appeals Tribunal (Uganda)

Case number

TAT Application 57 of 2021

Judges

Mugenyi, Chairperson, Mugerwa, Panel Member, Katwe

The Tribunal found that the applicant was liable for the tax assessments issued by the respondent. On WHT for nostro charges, the Tribunal held that the applicant, as the payer of management charges to foreign banks, was obliged to withhold tax under Ugandan law, regardless of whether the charges were passed on to customers. For VAT on initial customer deposits, the Tribunal determined that since the applicant claimed input VAT on the full invoice amount, it must also account for output VAT on the same amount, including initial deposits paid by customers to suppliers. Regarding disallowed int…

Source excerpt

• Vat Assessment
• Withholding Tax Obligation
• Input Output Vat Claims
• Interest Expense Deduction
• International Bank Charges
• Accounting Methods Tax

Apony Uganda Limited v Uganda Revenue Authority (Application TAT 80 of 2021)

Apony Uganda Limited v Uganda Revenue Authority (Application TAT 80 of 2021) [2023] UGTAT 7 (13 October 2023)

Court

Tax Appeals Tribunal (Uganda)

Case number

Application TAT 80 of 2021

Judges

Mugenyi, Chairperson, Mugerwa, Panel Member, Ali

The Tribunal held that Aponye Uganda Limited was part of a group with common underlying ownership, so its interest deduction was capped at 30% of EBITDA.

• Income Tax Assessment
• Interest Expense Deduction
• Group Company Definition
• Statutory Interpretation
• Tax Avoidance Provisions
• Income-tax