URA – Page 2 – MRT Tax

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

AI’s Disruption of Professional Services: The Rise of Niche Expertise.

The market now favors firms and individuals who deeply understand specific domains or sectors rather than generalists trying to do everything. A “niche within a niche” allows consultants to become irreplaceable for a defined audience or challenge set.

AI may also have provided the easy answer to the all important career decision question for senior consultants and executives in larger legacy firms; Which is whether to choose boutique independence over the politics, processes, and layers of bureaucracy that come with being part of a large firm

MRT Tax in Strategic Partnership with The Cragus Group—The GCC’s Leading Tax and Transfer Pricing Advisory Group

MRT Tax is pleased to announce a new strategic collaboration partnership with The Cragus Group, a ITR (World Tax) Top Tier Tax Firm headquartered in the United Arab Emirates (UAE).

Cragus is consistently ranked ahead of the Big 4 in the GCC, and is widely regarded as one of the region’s most trusted tax and transfer pricing firms, with a specialized oil and gas practice.

“This partnership bolsters our advisory capabilities, bringing together deep local insight and international oil and gas tax expertise for upstream, midstream and downstream investments currently being undertaken in East Africa’s oil and gas sector.” Remarked, Mark Ruhindi, the Managing Partner

Investing in Uganda; Tax Planning and Why Tax Should Lead Your Market Entry Strategy

The decision on corporate structure, i.e, whether to register a subsidiary vs. branch, Financing questions, i.e debt vs. equity, tax residence/domicile/location of holding entities are all strategy questions which are informed by tax considerations.

Choosing the wrong structure can expose the investor to; Transfer pricing risk, Withholding tax inefficiencies, Loss of treaty benefits, Double taxation and generally, tax inefficiency and a higher tax burden across different tax heads.

But what happens when the company is set up in a way that causes preventable tax leakages or unnecessary friction with the tax authorities?

For any foreign investor entering the Ugandan market, undertaking corporate legal structuring advice without any input from a tax practitioner is a grave mistake.

While the structure may be viable on paper, it might ignore certain critical elements of transfer pricing regulation, international tax treaty benefits and domestic tax compliance aspects that might later work against the investor and require a costly restructuring process.

2025 TAX AMENDMENTS; PROPOSED STAMP DUTY AMENDMENTS DO NOT CURE DEFECTS IN THE LAW

The Minister proposes an amendment to Schedule 2 to the Stamp Duty Act, to provide for nil duty for an agreement or memorandum of agreement executed or received in Uganda.

I need to warn at this point that Taxpayers better not celebrate just yet. This is because, the proposed amendment if passed into law might not in fact take away this liability. The Stamp Duty Act as it currently stands is littered with overlapping levies and one of these is the one the Minister proposes to do away with.

The tax sought to be done away with might still be brought home to a taxpayer by enforcing another provision. That other provision happens to be item 52 of Schedule 2 of the Stamp Duty Act, which levies Stamp Duty of a similar amount(Shs. 15000/=) on a RECEIPT as defined by section 2, for any money or other property the amount of value of which exceeds Shs. 50000 /=.

Section 2 of the Act defines the RECEIPT as follows;

“RECEIPT” includes a note, memorandum or writing whether the note, memorandum or writing is or is not signed with the name of a person,

(a) by which any money, or any bill of exchange, cheque or promissory note is acknowledged to have been received;

(b) by which any other movable property is acknowledged to have been received in satisfaction of a debt;

(d) which signifies or imports the acknowledgment;

The definition of a receipt under that Section is so wide that it in fact includes and indeed refers to what essentially is an agreement and a Memorandum of an agreement.