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From The Partners:
As we draw the curtains on 2025, we reflect on a year defined by transformative shifts in the tax landscape, from local, regional and international standpoints.
This year has not only tested the resilience of businesses in Uganda and across East Africa, but has also underscored the necessity of sophisticated tax expertise in an increasingly digital, tech-driven and transparent tax landscape, all of which now make tax scrutiny much easier for tax authorities.
2025 has also been a defining one for our firm across advisory, tax controversy, transactions practices, and we are grateful to our clients for the confidence placed in us through the sensitive and high‑stakes mandates we received, as you sought our guidance to help you navigate tax complexity with confidence.
We extend an equal amount of gratitude to our peers and collaborators–locally, regionally, and internationally.
A Year of Excellence, Collaboration, and Global Recognition
Our journey this year has been marked by significant milestones that reinforce MRT Tax’s position as a leading tax firm in Uganda.
Firm milestones during the year:
- Recognition and Rankings: MRT Tax received nomination for the International Tax Review’s prestigious Tax Firm of the Year Award – Uganda at the ITR EMEA Tax Awards 2025 and was subsequently recognised in the ITR World Tax 2026 rankings as a Notable leading tax practice in Uganda. The Founding Managing Partner, Mark Ruhindi received Individual Recognition as a Highly Regarded Practitioner-General Corporate Tax.
- Strategic Alliances: We entered into strategic collaborations with The Cragus Group, one of the GCC’s leading independent tax and transfer pricing firms, and Tax Consulting South Africa (TCSA), a market leader in taxation in South Africa.
These relationships significantly enhanced our ability to advise our clients in international trade on cross‑border structuring, transfer pricing, and international tax risk that crosses into those key trade and investment corridors and vice-versa.
- Market Engagement: Through MRT Insights, we continued to engage the market with experience‑driven analysis grounded in the firm’s live advisory, transactions and tax controversy work. Our commentaries on regional judicial developments, and enforcement trends, strengthened our role as a trusted interpreter of how tax rules are applied in practice.
Key Tax and Regulatory Developments Shaping 2025
2025 was ultimately shaped by broader developments cutting across the local, regional and international tax and regulatory environment. Across our engagements, several themes consistently emerged, including:
1. A Shift Toward Assertive, Tech and Data‑Driven Enforcement
The Uganda Revenue Authority (URA) transitioned into a more aggressive enforcement posture. We tracked the URA and KRA’s focus on the digital economy, payment systems, and third-party transaction data.
In our work over the course of the year, we observed that transparency, early tax treatment alignment strategies and reporting consistency proved decisive in repelling tax scrutiny. This is important because across the region, tax authorities including URA and KRA are increasingly “present” in taxpayers’ transaction flow throughout the business cycle, by leveraging technology.
2. Focus on the Digital Economy.
2025 marked a turning point in the taxation of the digital economy, as transaction data from payment intermediaries, digital platforms, VAT e-invoicing platforms and other integrated service providers becomes increasingly visible to tax authorities.
Across the region, VAT e‑invoicing moved decisively from a VAT leakage compliance tool, to a full-scale tax compliance and tax scrutiny tool covering all tax heads, majorly Income Tax.
This shift was also mirrored in the heightened enforcement of VAT e-invoicing, particularly regarding tax compliance in the real estate sector.
3. Regional Dynamics and International Taxation
In East Africa, Uganda’s Tax Appeals Tribunal provided much-needed clarity on EAC intra-trade VAT, streamlining how businesses navigate the regional customs union.
We analyzed the KRA v Sendy precedent from Kenya’s High Court, which sent shockwaves through the region’s digital commerce sector, threatening growth with complex VAT interpretations, highlighting the widening tax net around digital platforms.
On the global stage, we guided on the 2025 OECD Permanent Establishment(PE) rules update on remote workers, providing a vital roadmap for global companies managing cross-border human capital and entering new markets.
4. Private Wealth and the Diaspora
A pivotal shift occurred with the URA’s “Diaspora Wealth Notices.” Our insightful commentary on taxation of offshore asset holdings and foreign-sourced income have been critical for clients navigating this enforcement frontier, ensuring that wealth built abroad is protected through proactive tax planning.
Looking Ahead – What We Expect in 2026
If 2025 marked an acceleration in enforcement capability, 2026 is likely to be defined by consequence management.
Based on observed trends, we expect:
- Tax Controversy: We anticipate a rise in tax scrutiny, and therefore tax litigation. Businesses must ensure that their tax positions are contemporaneously documented; waiting for an assessment to arrive before seeking tax advice is no longer a viable strategy. This would ensure defensible tax positions, contemporaneous documentation, and early dispute readiness.
- Tech and Data: We anticipate deeper deployment of technology by tax authorities: AI, data analytics and third‑party information will take centre stage in tax scrutiny processes.
- Digital Platforms: A Continued focus on the digital economy is expected, alongside a push to close leakages from Uganda derived income earned by global tech firms and scrutiny of remote cross-border work arrangements, following the recent OECD update on permanent establishments.
- Tax Incentives: We expect an increased scrutiny of tax incentives and exemptions, with a clear preference for substance over form, and a denial of exemption status where qualifying conditions are not met.
Closing Reflections
For businesses, Tax strategy must now be embedded into; Governance& Corporate structuring, Commercial processes, Transactions(M&A, Asset Acquisitions and Dispositions) planning, and Scaling and expansion(both local and cross-border) decisions from the outset.
At MRT Tax, our role remains to help you anticipate these risks and to guide your inhouse team on confidently navigating the increasingly sophisticated tax environment.
We thank you for your continued trust and look forward to a prosperous 2026.
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