As we enter the year ahead, we remain firmly aligned with your business objectives, to continue to deliver unrivaled technical acumen in managing each and every one of your mandates across tax and business law, and with the same value proposition of Integrated Tax and legal Excellence, through our two integrated professional services arms.
Tag Archives: TAX LAWYERS UGANDA
MRT Tax 2025 Year in Review: The Market and Key Tax Trends
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.
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.
Recognition and Rankings:
MRT Tax received nomination for the 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.
KRA Vs Sendy: Kenya’s High Court VAT Precedent Threatens East Africa’s Gig Economy and Digital Commerce Growth.
Kenya’s High Court has recently delivered a Key decision in the battle over VAT in the ride-hailing/digital platform economy, that risks far-reaching ripple effects across East Africa’s digital commerce landscape.
The landmark decision fundamentally reclassifies digital platforms as primary suppliers of gig-economy services for VAT purposes. This brings them fully into the VAT net and forces gig workers/entrepreneurs and small merchants into VAT compliance, with potentially far-reaching consequences for the growth, structure, and taxation of the East African digital economy.
The immediate tax implication is that we now have two VATable transactions in every ride or delivery processed through a digital platform operating a similar business model. These are;
Supply from motor vehicle owner to tech platform (input VAT for the platform)
Supply from tech platform to end consumer (output VAT to the tax authorities on full final consideration paid by the end consumer)
This new reality is problematic from a commercial point of view, taking into consideration the nature and level of tax sophistication of most African economies.
The other immediate implication is that thousands of gig-economy participants have been hit with a VAT compliance shock overnight, and the reason is simple; e-commerce platforms lose input VAT if they trade with non-compliant taxpayers. Exposure to commercial activities of too many Non-VAT Traders or informal taxpayers makes the platform’s business model commercially unviable and wipes out margins.
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.
MRT Tax in Strategic Partnership with Tax Consulting South Africa (TCSA)—A Leading Independent South Africa Tax Firm
MRT Tax is pleased to announce a strategic collaboration partnership with Tax Consulting South Africa (TCSA), one of South Africa’s foremost independent tax firms.
TCSA has established itself as the go-to firm for sophisticated, high-stakes tax advisory across the Southern African market, offering an unmatched combination of technical depth, innovation, and regulatory insight. With a multi-disciplinary team of tax attorneys and chartered accountants, TCSA consistently sets the standard for independent tax excellence in South Africa — and increasingly, across the continent through a professional services partner network presided over by the firm’s leaders.
As regional trade and investment flows between East and Southern Africa continue to accelerate, our clients increasingly require seamless, multi-jurisdictional tax support. Through this partnership, MRT Tax brings deep East African market knowledge and advisory experience in corporate and transaction tax, while TCSA contributes its leading capabilities in South African and cross-border tax compliance, expatriate taxation, and international tax structuring.
“This partnership enhances our ability to deliver coordinated, high-quality advisory across key African jurisdictions. It’s about ensuring that our clients, wherever they operate on the continent, have access to trusted, technically sound, and independent tax advice,” remarked Mark Ruhindi, Managing Partner MRT Tax.
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.