International School of Uganda v Uganda Revenue Authority (Taxation Application No. 16 of 2016)
International School of Uganda v Uganda Revenue Authority (Taxation Application No. 16 of 2016) [2018] UGTAT 4 (20 December 2018)
The Tribunal found that the applicant, while a non-profit educational institution, is privately owned, funded, and managed, with accessibility limited by high fees and an international curriculum. Applying statutory interpretation, the Tribunal held that 'public character' under S. 2(bb) of the Income Tax Act requires more than mere accessibility; it encompasses ownership, funding, management, and the extent of public benefit. The applicant's structure and operations overwhelmingly reflect private rather than public character. The accumulation of large reserves and income from non-educational…
Source excerpt
- Income Tax Exemption
- Educational Institutions
- Public Character Test
- Statutory Interpretation
- Tax Administration