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Tax Law [2024] UGCommC 22

Uganda Revenue Authority v Whistleblower (REF. TID 170819150)

Uganda Revenue Authority v Whistleblower (REF. TID 170819150) (Civil Appeal 30 of 2021) [2024] UGCommC 22 (16 January 2024)

The respondent's right to a whistleblower reward under section 8 of The Finance Act, 2014 was contingent upon actual recovery of tax, not merely provision of information. At the time of the statutory amendment reducing the reward rate to 5%, the respondent had not acquired a vested right, only a contingent interest. The applicable law is that in force at the time the claim becomes enforceable, which is upon recovery, not at the time of information provision. The Tax Appeals Tribunal erred in applying the repealed statute and awarding a 10% reward and excessive interest. The appeal succeeds; t…

  • Statutory Rights
  • Retrospective Application
  • Whistleblower Rewards
  • Unilateral Contracts
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