A Market-Leading Tax Litigation Practice: MRT Tax|Spatium Advocates

MRT Tax|Spatium Advocates, operates one of Uganda’s leading Tax Dispute Resolution and Tax Litigation practices.

Our people are recognized leaders in tax and some of the most distinguished tax professionals in Uganda and the East African regional market. And our firm widely recognized as the go-to firm for complex, high-value, and precedent-sensitive tax disputes, acting for corporates, multinationals, financial institutions, investors, and high-net-worth individuals.

The strength of our tax disputes practice lies in the seamless integration of our unmatched technical tax and transfer pricing expertise with litigation and advocacy capabilities.

This collaboration allows us to:

Control disputes from audit to final appellate determination.

Combine technical tax analysis that borrows from both tax and transfer pricing with procedural, constitutional, and evidentiary advocacy. This enables us to litigate complex tax matters with clarity, credibility, and authority.

Unlike advisory-only tax practices, we are structured for enforcement, objections, and courtroom. And unlike general litigation firms, we bring deep tax and transfer pricing technical mastery into every dispute.

This integrated model has positioned the MRT Tax|Spatium Advocates tax disputes collaboration as Uganda’s foremost tax controversy team.

Our dispute practice regularly handles audits and litigation arising from digital commerce taxation, including digital services taxes, PE assertions, and transfer pricing challenges.

Our Tax Dispute Resolution Capabilities.

We represent taxpayers across the entire tax dispute lifecycle, including:

1. Tax Audits and Investigations

We act for clients from the earliest stage of engagement with the Uganda Revenue Authority (URA), including:

Audit readiness and exposure assessment.

Strategic engagement, correspondence and information flow management with URA.

Preparation of technically and legally defensible audit responses.

Our objective at audit stage is risk containment, while preserving litigation leverage should the dispute escalate.

2. Objections to Tax Assessments.

We are widely known for our strength in tax objections, including, handling:

Income tax, VAT, and withholding tax assessments.

Transfer pricing adjustments.

Penalties, interest, and enforcement-related assessments.

Customs and indirect tax disputes.

Our objection work is forensic, evidence-driven, and litigation-oriented, frequently resulting in assessments being withdrawn, reduced, or strategically repositioned.

3. Tax Appeals and Litigation.

Where disputes progress beyond the objection stage, we provide robust representation before tax appeals tribunal and courts, including:

Tax decision review applications before the Tax Tribunal and Appellate proceedings.

4. Transfer Pricing and Complex Tax Disputes.

MRT Tax is particularly recognized for handling highly technical, high-value disputes, including:

Transfer pricing audits and litigation

Permanent establishment disputes

Recharacterisation of income and expenses

Cross-border and international tax disputes

These matters demand both economic analysis and courtroom advocacy, an area where our collaboration culture is especially powerful.

5. Penalties, Interest, and Enforcement Actions

We regularly challenge:

Administrative penalties and surcharges

Excessive interest assessments

Agency notices and recovery actions

Asset attachment and enforcement proceedings

Our strategy focuses on statutory compliance, proportionality, and taxpayer rights, often achieving significant exposure reduction.

6. Strategic Settlement and Dispute Resolution

While we are fully prepared to litigate, we also advise on:

Strategic ADR settlement negotiations

Risk-weighted dispute resolution

Cost-benefit analysis of litigation versus alternative dispute resolution

Preservation of long-term regulatory and commercial relationships

This ensures outcomes that align with both legal strength and commercial realities underpinning a dispute.

Industries We Serve:

Our tax dispute practice spans all major sectors of the economy, including:

Banking and Financial Services

Telecommunications and Digital Economy

Energy, Mining, and Extractives

Manufacturing and Trading Groups

Real Estate and Infrastructure

Private Equity and Investment Structures

Import and Export Trade

Pharmaceuticals and Medicaments

This breadth gives us deep insight into sector-specific enforcement trends and URA focus areas.