Explorer Limited v Uganda Revenue Authority (Application 87 of 2023)
Explorer Limited v Uganda Revenue Authority (Application 87 of 2023) [2024] UGTAT 3 (31 October 2024)
The Tribunal found that the Applicant had adequately demonstrated the existence of a shareholder loan through a loan agreement, financial statements, and a letter extending the loan term. The Tribunal held that it was unreasonable for the Respondent to demand transactional documentation dating back nearly 20 years, especially when the statutory record-keeping requirement is five years. The Tribunal emphasized that the Respondent's power to recharacterize transactions must be exercised judiciously and rationally, and that in this case, the Respondent failed to provide evidence linking the Appl…
Source excerpt
- Income Tax Assessment
- Related Party Transactions
- Burden Of Proof
- Anti Avoidance Rules
- Substance Over Form
- Statutory Record Keeping