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MARK RUHINDI
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Tax Legislation Alert: April 2026
Uganda’s 2026 tax amendment bills are best read together, not in isolation. Taken as a package, they point to a set of key policy tweaks that includes: widening the tax base, moving collection closer to the point of payment, hardening digital compliance, and preservation of only a limited set of targeted incentives.
Across income tax, VAT, excise duty, stamp duty, tax procedure, gaming, and road-use regulation, the direction is broadly the same: expand the effective tax net, improve collection at source, tighten compliance administration, and preserve only a limited number of targeted incentives.
The commercial significance of this package lies not only in tax rates. It lies just as much in timing, cash-flow impact, and compliance structure. Several of the proposals move tax collection closer to the payment event itself. Others raise transaction costs directly. Others still make the digital compliance framework harder to ignore. Taken together, the package will matter to employers, lenders, investors, contractors, telecom operators, gaming businesses, developers, manufacturers, importers and high-net-worth individuals.
Income Tax: the broadest and most commercially important bill
The Income Tax (Amendment) Bill, 2026 is the centrepiece of the package. The bill proposes a combination of base-expanding measures, new withholding mechanisms, targeted exemptions and revised individual tax bands.
Among the most important proposals are: express inclusion of software in the royalty definition, inclusion of income from disposal of a non-business asset, a new tax burden on long-carried losses, withholding tax on qualifying debenture interest paid abroad, withholding on non-business asset purchases, withholding on betting or gaming winnings, broader telecom commission withholding, withholding on resident public entertainers, and an express rule that foreign-source income of a resident individual is taxed at the same rate as the equivalent Ugandan-source income.
The bill also extends Bujagali’s exemption to 30 June 2032, introduces a hotel and tourism facility exemption, adds BADEA and Uganda Red Cross Society to Schedule 2, and revises the resident individual rate bands.
The controversial clauses
The most controversial proposal is likely to be the new rule on long-carried losses. The bill provides that where a taxpayer continues to carry forward assessed losses after seven years, the taxpayer must pay tax at 0.5% of gross income or the tax under section 4(1), whichever is higher. The current position is that the ordinary income tax framework remains profit-based, even though losses are already subject to limitation rules.
The proposed change is therefore significant because it introduces a minimum-tax style result for taxpayers that may still be commercially loss-making. The commercial effect is potentially severe for capital-intensive or long-gestation businesses, including infrastructure, hospitality, extractives, agribusiness and early-stage ventures.
The proposed 5% withholding tax on qualifying debenture interest paid by a resident company to a non-resident is also commercially important. Under the current position, the existing regime continues to apply.
The bill would require withholding on the gross interest amount, at a rate of 5%, where the statutory conditions are met. The commercial effect is that this is likely to increase the cost of cross-border debt. In many financings, that cost is ultimately borne by the Ugandan borrower either directly or through pricing adjustments.
Relief for low-income earners
The bill also raises the nil band for resident individuals to UGX 4,020,000, introduces a 25% middle band, and retains the 30% rate structure with the additional 10% on income above UGX 120,000,000.
This is one of the more taxpayer-friendly features of the bill, and it appears designed to offer some relief on employment income even as the wider bill becomes more assertive on withholding and tax base expansion.
VAT: relief for compliant transactions, but tighter digital and project-specific rules
The VAT bill is more mixed in character. Under the current law, the existing VAT withholding, registration threshold and refund rules remain in place. The bill proposes to disapply VAT withholding where a designated person pays for taxable supplies and is issued with an e-invoice or e-receipt.
It also increases the VAT registration threshold from UGX 150 million to UGX 250 million, introduces a targeted input credit for qualifying hotel or tourism facility developments, provides that the software-related restriction applies only to imported software, allows regulations on payment of tax for plant, machinery and mining inputs, changes the refund-related amount from UGX 50,000 to 5% of the refund claimed, reduces the relevant section 38 amount from UGX 5 million to UGX 2 million, adds BADEA and updates the Medical Research Council listing, and extends Schedule 3 relief to nuclear energy contractors and subcontractors.
The higher VAT registration threshold is likely to be welcomed by smaller businesses because it removes some businesses from the full burden of VAT registration and ongoing compliance. The EFRIS-linked withholding carve-out is also commercially sensible: where the transaction is already visible through e-invoicing or e-receipting, the law appears willing to rely less on withholding as a separate enforcement mechanism. By contrast, the refund-related changes and the imported software wording indicate that the VAT system is still moving toward closer digital control and more precise input tax boundaries.
Excise Duty: immediate price effects across the market
The Excise Duty bill is likely to be felt fastest in the market because excise changes move quickly into consumer and business pricing. The bill proposes revised rates for imported undenatured spirits of less than 80% alcohol strength, cement and related products, petrol, diesel, sugar, plastics, cooking oil, motorcycles at first registration, paints, varnishes, lacquers, and cooking fat. Among the proposed figures are UGX 1,750 per litre for petrol, UGX 1,430 for diesel, UGX 1,000 per 50kg for cement, UGX 300 per kg for sugar, UGX 400 per litre for cooking oil, and UGX 500,000 on motorcycles at first registration.
The commercial effect here might arise out of the fact that higher fuel duties feed into transport and supply chain costs.
- Higher duties on cement, paints and related products affect construction and real estate.
- Higher duties on sugar, cooking oil and cooking fat affect household and FMCG pricing.
- Plastics changes affect packaging and manufacturing.
This is the part of the legislative package most likely to transmit quickly into inflation-sensitive pricing decisions.
Stamp Duty: a smaller bill with real transactional impact
The Stamp Duty bill is narrower, but it carries meaningful transactional consequences. Under the current law, the existing stamp duty rules continue to apply.
The bill would require persons carrying on the business of financial services to file monthly returns of sums received in respect of stamp duty paid on instruments, require retention of dutiable records for at least five years, increase duty on transfers to 3% of total value, and introduce fixed stamp duty on registration or transfer of motorcycles, tricycles, quadricycles and other motor vehicles. It also imposes 2% simple interest per month where the financial services monthly return is not filed.
The most significant commercial issue is the increase in duty on transfers to 3%. That raises the cost of transfer transactions, especially in property and asset-related dealings.
The monthly reporting requirement for financial service providers also shows that the broader policy trend is to turn intermediaries and collection points into formal compliance channels.
Tax Procedures Code: relief for legacy debt, but harder digital penalties
The Tax Procedures Code bill combines relief and enforcement.
The bill proposes three notable changes: the figure in section 21(3) is reduced from 2,500 currency points to 100; a new section 47C waives any tax, penal tax and interest owed as at 30 June 2016 and still outstanding at commencement; and section 93 is replaced so that failure to use an electronic fiscal device, failure to issue an e-invoice or e-receipt, or tampering with a device attracts penal tax equal to double the tax due or ten currency points, whichever is higher.
The commercial message is mixed but clear: The government is prepared to clear very old tax debt from the system, but it is not relaxing its approach to current digital compliance.
On the contrary, electronic receipting, invoicing and fiscal device compliance appear to remain central to the enforcement model. Businesses that still treat EFRIS compliance as secondary should assume that the law is moving in the opposite direction.
Lotteries and Gaming: higher certainty, heavier sector focus
The Lotteries and Gaming bill is short, but important.
The bill proposes to harmonise the gaming tax rate for betting or gaming activity at 30% of the total amount staked less payouts, and it defines payouts more fully as the gross amount transferred or credited to a player as a result of a winning outcome, without deduction for the amount staked.
The commercial effect is that the sector moves to a more uniform charging basis, while the State also tightens definitional clarity. Read together with the Income Tax bill’s separate withholding on betting or gaming winnings, the policy direction signals an intention to make revenue mobilisation inroads deeper into the sector, both on the operator side and the player-payment side.
Traffic and Road Safety:
The Traffic and Road Safety bill sits outside the core tax statutes, but it has obvious fiscal and market consequences.
The bill proposes to reduce the import age limit from fifteen years to thirteen years, while also introducing a graduated levy structure for imported vehicles aged nine to twelve years, ranging from 20% to 50% of CIF value. A transitional rule excludes vehicles already in transit before commencement, provided they arrive in Uganda by 31 December 2026.
The commercial effect is clear: older imported vehicles will become less accessible and more expensive to bring into the Ugandan market. That may support environmental and fleet renewal policy, but it also raises acquisition costs for dealers, logistics operators and consumers in a market where used imports remain commercially important.
Conclusion
Viewed as a package, the 2026 amendment bills are not simply a technical clean-up exercise. They reveal a broader policy choice: collect earlier, digitise harder, widen the taxable perimeter, and reserve relief for a limited number of targeted sectors and taxpayer groups.
The bills signal a more intentional approach to tax mobilisation, with the tax and compliance environment becoming more immediate, more digital, and more transaction-focused. The recurring pattern across the package is that tax will increasingly be collected earlier, through more visible systems, and with less room for informality once a transaction has been priced, invoiced or paid.
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