Uganda’s FY 2026/27 Budget and Tax Amendments: Revenue Mobilisation and the Business Resilience Test.

The FY 2026/27 Budget for Uganda focuses on full monetisation and growth through enhanced domestic revenue mobilisation, digital compliance, and targeted tax amendments, while aiming for fiscal self-reliance.

The Budget emphasizes job creation, sector-specific support, and infrastructure investment. However, the implications for businesses and taxpayers include a shift towards a more digitised and compliance-heavy tax environment, with selective relief measures that may not cushion broader economic pressures.

Challenges such as increased costs for fuel, construction materials, and the contemplated higher regulatory compliance costs necessitate proactive strategies from businesses to navigate this demanding fiscal landscape and ensure resilience amid changing tax dynamics.

Deemed Disposals Capital Gains Taxation in Uganda: Residence and Control Changes(M&A), Insights from Kuku Foods(KFC) v URA

The Tax Appeals Tribunal (TAT) recently issued a landmark ruling in Kuku Foods Uganda Limited v Uganda Revenue Authority, reshaping how indirect corporate restructurings and ownership changes are taxed in Uganda.

The dispute arose from a Uganda Revenue Authority (URA) Capital Gains Tax (CGT) assessment of approximately UGX 4.235 billion levied against Kuku Foods Uganda Limited — the local operating entity of the KFC franchise following an offshore shareholding reorganization.

Key Commentary Bottom-line:

Uganda taxes changes in tax nexus through statutory realisation rules. The rules put in place deemed disposal or deemed realisation events, where Capital Gains Tax liabilities will arise, even where no ordinary commercial sale of an asset has occurred.

Where a taxpayer enters residence, the Income Tax Act protects both the taxpayer and the revenue authority by fixing the opening cost base of relevant assets at market value.

Where a taxpayer exits residence, the Act may impose an exit charge by deeming a disposal at market value.

Where a company located in Uganda undergoes a qualifying change in ownership, the Act may deem the company itself to have realised its assets and liabilities at market value.

Uganda’s Digital Services Tax Landscape in 2026 vs Pillar Two, Global Minimum Tax and the OECD’s Side-by-Side Package.

The international tax landscape continues to transform rapidly in response to the twin pressures of digitalisation and profit shifting by multinational enterprises (MNEs). Many low- and middle-income countries, including Uganda, have adopted unilateral Digital Services Taxes (DSTs) as an interim measure to ensure that digitalised businesses with minimal physical presence nonetheless contribute tax where economic value is created.

These unilateral measures emerged against the backdrop of stalled consensus on a coordinated global response to the taxation of digital activities under the Organisation for Economic Co-operation and Development (OECD) and G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), Pillar Two.

However, as we enter 2026, the international tax policy environment has shifted again, notably with the recent agreement by over 145 jurisdictions on a revised global minimum tax package aimed at preserving taxing rights of jurisdictions where these MNEs operate through digitalised business models that require little or no physical presence. 

This agreement does not abandon Pillar Two; rather, it modifies its application through a “side-by-side” framework that allows certain jurisdictions, most notably the United States to operate parallel domestic minimum tax regimes while still achieving the policy objective of a 15 % global minimum tax.

This article explains where DST sits in this evolving framework, clarifies key positions from earlier DST debates, and assesses the implications of the side-by-side global minimum tax agreement for both DST regimes and broader international tax cooperation.