Category Archives: TAX LAWYERS

Uganda’s 2026 Tax Amendment Bills: A Practical Guide to the Main Changes and Their Commercial Impact.

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.

ITR World Tax 2026 Rankings: MRT Tax among Top Tax Firms in Uganda.

We are delighted to share that MRT Tax has been ranked among the Top tax firms in Uganda in the newly released ITR World Tax 2026 rankings

In addition, the firm’s Managing Partner, Mark Ruhindi, has been individually recognized as a ‘Highly Regarded’ practitioner in General Corporate Tax – (The Highest Tax Leader Rating), underscoring his standing as one of Uganda and East Africa’s leading tax professionals.

This achievement follows MRT Tax’s earlier nomination for the “Tax Firm of the Year (Uganda)” Award at the International Tax Review (ITR) EMEA Tax Awards 2025—a ceremony that celebrates the most distinguished tax and transfer pricing professionals and teams across 33 jurisdictions in Europe, the Middle East, and Africa.

These milestones hold particular significance for us, being the youngest practice to attain recognition within this elite category — in a competitive market historically dominated by global accounting networks and long-standing decades old law firms.

East Africa Trade: Uganda’s Tax Appeals Tribunal clarifies on EAC Intra-Trade VAT

The Tax Appeals Tribunal has delivered a landmark decision that strikes at the heart of URA’s aggressive enforcement and over-reach tendencies and restores the much-needed balance in the taxpayer-taxman relationship.

(TRADE WORTH ESTABLISHMENTS LTD V URA TAT APPLICATION 338 OF 2024)

In perhaps the strongest language yet from the Tribunal against the revenue body, TAT observed:

“On the whole, we find that the Respondent acted not only unlawfully but also with impunity and in total abuse of their powers and authority… Rather than doing this [refund VAT unlawfully collected], the Respondent orchestrated a phoney scheme to deny the Applicant their refund – a taxpayer, who is the very reason for the Respondent’s existence.”

Citing its earlier decision in Canaan Sites Limited v URA, TAT further emphasises the ethical and legal obligation of URA to return taxes not legally due: “Where the Respondent collects taxes that are not legally owed, it is generally expected to refund those amounts to the taxpayer… it has an ethical and legal obligation to return those funds to maintain trust in the tax system.”

Uganda Revenue Authority goes after the Digital Economy: Payments Systems and third-Party Transaction Information in Tax Administration.

Whereas the digital economy is mostly composed of digital companies and the web-based commercial marketplace, the brick-and-mortar businesses are also covered since most now take payment through digital payment systems.

What this means is that digital payment systems now permeate nearly every sector, blurring the line between the traditional and digital economy.

The internet marketplace and the digital economy are data-driven and therefore I anticipate the next stage of the government’s tech-driven tax compliance enforcement campaign to be deployment of big data analytics and artificial intelligence in building taxpayer profiles using third-party payments and financial services information to flag transactions that would otherwise have escaped the tax net.

Sectors such as E-commerce, Gaming, Financial Services (fintech), and Telecoms process hundreds of thousands and for some, even millions of daily transactions.

Unlike a few years ago when tax authorities had no means of scrutinising such an
overwhelming volume of transactions and to assess tax upon each and every one including the tiniest of transactions.

Currently, Tax Authorities are able to rely on advanced data analytics and the deployment of artificial intelligence tools to track tax on even the smallest of transactions.

Uganda VAT E-INVOICING(EFRIS) Enforcement: Compliance Insights for Landlords and Tenants.

While initially criticised as premature and fought by taxpayers especially those under the KACITA umbrella, it appears the system is here to stay and has increasingly become the backbone of Uganda’s tax administration.

For commercial property landlords, who fall within the VAT net, strict EFRIS compliance marks a significant shift and fundamentally alters governance and tax reporting obligations for entities, which in turn poses risk to investments controlled under those entities.

The reason is simple; VAT administration directly intersects with income tax and rental tax compliance in a manner many lay taxpayers do not yet appreciate. The increased VAT scrutiny through EFRIS has a direct bearing on the landlord’s other tax compliance obligations under income tax and rental tax.

Landlords and property managers must therefore consider adjusting operating models to align with URA’s strict stance, as informal practices will expose them to heavier tax risk through deduction disallowances, penalties, additional tax assessments and a heavier professional fees burden.

Government Contract Bidding in Uganda: Key Tax Considerations for Bidders and Contractors.

Having regard to the sector, nature and scale of a taxpayer’s commercial activities, a government contractor, an investor trying to structure a government contracting arm of an existing business, might need to try to appreciate the Tax Exemptions regime and how it applies to both their existing and future contracts with the government, across the different tax heads.

When bidding for government contracts in Uganda, one of the most critical but often overlooked areas of tax due diligence is the identification and navigation of tax advantages available to the contractor, in the form of exemptions and reduced duty rates under the different tax heads.

The proper utilisation of exemptions not only ensures tax compliance but also creates direct tax savings that can materially influence the competitiveness of a bid and ultimately, the profitability of the project.

Uganda’s Real Estate Sector Faces Heightened Tax Scrutiny

Commercial activities in Uganda’s Real Estate sector have not been subjected to the same level of tax scrutiny as other lucrative industries, largely due to the informal character of the bulk of transactions and real estate activities generally.

We now expect more audits in the Real Estate Sector and transactions that have since been concluded and those to be concluded going forward.

And so Taxpayers in real estate may now need to take steps to fully formalize their activities for compliance purposes under the different tax heads.

MRT Tax nominated for “Tax Firm of the Year – Uganda” at the ITR EMEA Tax Awards 2025.

We’re honored to share the great news that our firm is shortlisted for “Tax Firm of the Year – Uganda” at the Prestigious International Tax Review’s ITR EMEA Tax Awards 2025.

The ITR EMEA Tax Awards was established in 2005 to commend tax professionals and their practice accomplishments over a 12-month timescale.

This year’s 21st annual awards highlights the most distinguished tax and transfer pricing professionals and teams across 33 jurisdictions in the EMEA region(Europe, Middle East and Africa).

This recognition is more than just a nomination—it’s a testament to the growing influence of our firm within Uganda and East Africa’s complex and evolving tax landscape.

It reflects our team’s commitment to technical excellence, client trust, and innovation in delivering forward-thinking tax solutions to the market.

We are immensely proud of what the recognition represents to both the firm, our partners and clients.

From humble beginnings, we’ve built MRT Tax into a firm trusted by some of the country’s most dynamic businesses and we continue to be a trusted guide to investors of all categories navigating market entry into this market and beyond.

We’ve established partnerships with some of the world’s leading firms and practitioners and are on course to consolidate our position as a top-tier firm.

The nomination is also a powerful vote of confidence from both our peers and clients.
On behalf of the teams at MRT Tax and its sister and collaborating firms, We would like to thank you all for believing in us and for entrusting us with the opportunity to provide answers and solutions to your most complex and high-stakes legal and tax matters over the past year.

We would also like to congratulate our partners and colleagues who have been Shortlisted in other jurisdictions on your well-deserved recognition. Ends

Uganda’s FY 2025/26 Budget: A Filtered Tax Guide.

This commentary provides a tax guide through a practitioner’s lens on key tax policy measures and budget implications, emphasizing the following policy propositions in the Minister’s Speech.
Penalty waivers on interest and tax arrears, Tax exemptions for Start-Ups, Domestic revenue mobilization and Tax enforcement implications of the planned revenue mobilization measures. The guide further distills the speech and highlights key takeaways on what entrepreneurs, and business leaders at the helm of startups, SMEs and large businesses need to know, particularly on Tax waivers, Tax exemptions, planned Reduction in domestic borrowing, Reduction of domestic arrears and Investments in oil and gas and Infrastructure. Read on below;

A CORPORATE GOVERNANCE MASTERCLASS FOR ENTREPRENEURS FROM THE HUMPHREY NZEYI v BoU CASE.

While shareholders own the company, they DO NOT own the assets of the company. The assets they own are the shares allotted to them. The company owns its assets. Conversely, the shareholders are not the managers of the company. They must first become directors in law for them to exercise managerial roles.

The directors(the Managers) owe a fiduciary duty to the company as ‘a whole’. This fiduciary duty requires directors to act in good faith and in the long-term interests of the entity, balancing the interests of both shareholders and creditors.

This is because the total assets of a company are composed of shareholder equity+liabilities (i.e. creditor interests). For the section of my readership without an accounting background, in law this is the starting point of the accounting equation. The company as a legal entity is therefore subject to these two competing legal(or equitable) claims.

The directors’ duty to act in the company’s best interests logically includes the obligation to weigh and balance these interests at all times.

When a company enters financial distress, the law demands that the board begin to prioritize the interests of creditors alongside those of shareholders and certain transactions are outright void at law in extreme circumstances where this principle is breached.

Good Corporate governance and Board composition matters. A competent, diverse board is better equipped to navigate financial stress and generally, the intricate market and regulatory dynamics in which the company operates. Ensure you have a blend of directors with expertise in risk, tax, legal, and operations as opposed to just investors, friends or family members.