Strategic Advisory, Documentation, and Dispute Resolution for Related-Party Transactions

Transfer pricing has become one of the most scrutinized and contentious areas of tax and regulatory enforcement in Uganda and across the East African region.

Revenue authorities are increasingly focused on related-party transactions, value allocation, and profit shifting, making transfer pricing compliance and dispute management a critical risk area for multinational groups, regional businesses, and investment structures.

Our Transfer Pricing Capabilities

MRT Tax has built strong specialized end-to-end transfer pricing advisory capabilities, combining technical tax analysis and litigation expertise.

We advise multinational enterprises, regional groups, private equity-backed structures, and owner-managed businesses with cross-border or domestic related-party transactions.

Our approach is practical, evidence-driven, and dispute-ready, recognizing that transfer pricing is no longer a theoretical exercise but a high-stakes enforcement battleground.

Our practice supports clients through compliance, documentation, audits, objections, and litigation, ensuring that intercompany arrangements are defensible, commercially grounded, and aligned with both Ugandan law and international best practice, including OECD principles.

Our team is deeply experienced in engaging with the Uganda Revenue Authority (URA) and in defending clients in tax objections, assessments, and litigation before the Tax Appeals Tribunal.

Our clients are able to benefit from our international taxation and transfer pricing expertise that spans double taxation treaty tax planning, transfer pricing documentation and compliance, transfer pricing audit support and dispute resolution throughout the business cycle.

We also advise extensively on Digital Commerce Taxation, particularly where transfer pricing, intangibles, and digital business models intersect in African and cross-border markets.

Core Areas of Focus

1. Transfer Pricing Compliance & Documentation

We assist clients in establishing and maintaining robust, audit-ready transfer pricing frameworks, including:

Preparation and review of transfer pricing documentation.

Local file and master file support

Functional, asset, and risk (FAR) analysis.

Benchmarking and economic analysis.

Intercompany pricing policy design and implementation.

Compliance with Ugandan transfer pricing regulations and OECD guidelines.

Our documentation is designed not merely to satisfy formal requirements, but to withstand regulatory scrutiny and litigation challenge, with clear commercial narratives supported by evidence.

2. Structuring of Related-Party Transactions

We advise on the transfer pricing implications of complex intercompany arrangements, including:

Management fees and shared services arrangements.

Royalties, intellectual property licensing, and cost contribution arrangements.

Cash pools, Intercompany loans, guarantees, and financial transactions.

Supply chain restructuring and distribution models.

Head office and management fee charge structures and regional operating models.

Our focus is on ensuring that pricing outcomes are commercially justifiable, legally defensible, and aligned with value creation, while minimizing exposure to penalties, adjustments, and double taxation.

3. Transfer Pricing Audits and Investigations

Transfer pricing audits are increasingly lengthy, intrusive, and adversarial. We represent clients throughout the audit lifecycle, including:

Pre-audit risk assessments and readiness reviews.

Strategic engagement with revenue authorities.

Preparation of audit responses and technical submissions.

Managing information requests and interviews.

Settlement negotiations and risk mitigation strategies.

We approach audits with a litigation mindset, ensuring that every submission is defensible and strategically positioned in anticipation of potential dispute escalation.

4. Transfer Pricing Objections, Appeals, and Litigation.

MRT Tax|Spatium Advocates, is home to one of the strongest tax dispute resolution teams in Uganda. We represent clients in:

Objections against transfer pricing assessments.

Appeals before the tax tribunal and litigation before Ugandan courts.

Penalty and interest disputes arising from transfer pricing adjustments.

Our litigation strategy integrates technical transfer pricing analysis with procedural and constitutional tax law arguments, ensuring that disputes are contested on both substantive and legal grounds.

5. Advance Risk Management and Dispute Prevention

Recognizing the cost and disruption of transfer pricing disputes, we support clients with proactive risk management, including:

Transaction pre-clearance and risk assessment.

Policy refreshes following business or regulatory changes.

Internal governance and audit support

Alignment of legal agreements with pricing outcomes.

Advisory on documentation retention and evidentiary strategy.

This proactive approach allows clients to identify and address risk before it crystallizes into enforcement action.