URA loses tax exemption case against ten companies

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Court has dismissed a case in which the Uganda Revenue Authority (URA) had sought to tax ten Ugandan-incorporated companies engaged in regional trade of assorted agricultural produce.

The Commercial Division of the High Court, presided over by Justice Susan Odongo, on April 11, 2026, dismissed the case on the grounds that agricultural goods are exempt from withholding tax.

“In conclusion, I find that the tax tribunal appeal did not err in law," ruled Odongo.

"The respondents’ goods are agricultural supplies within the ordinary meaning of the Income Tax Act and the non-discriminatory spirit of the East Africa Community Protocol because these supplies are exempt by statute under Section 136(5)(c) of the possession of a withholding tax exemption certificate was not a legal prerequisite for their entry. The appellant’s demand for tax was therefore an act outside the corners of the law required."

The ten companies are;

▪️Nyanga Oburofa Enterprise Limited

▪️Harry Transporters Limited

▪️Rapada Uganda Limited

▪️Tesla Technical Services Limited

▪️Xtreme Uganda Limited

▪️Gersa Holdings Company Limited

▪️Goldcoast Cargo Hauliers Limited

▪️Nakabira Enterprises Uganda Limited

▪️Nkutu General Contractors Limited

▪️Abasi Balinda Transporters Limited

The above-mentioned companies challenged a tax assessment issued by URA at the Tax Appeals Tribunal, which ruled in their favour.

Dissatisfied with the decision, URA, through its legal officers, Lydia Katami and Rodney Amanya, appealed to the Commercial Division of the High Court, which also dismissed the case.

The dispute involved the ten companies engaged in regional trade of agricultural commodities such as rice, beans, sorghum, and soya beans, which they import from Tanzania for sale in the Ugandan market.

The companies, represented by lawyers Sydney Ojwee and David Amanya, had argued that the goods were exempt from tax under Section 136(5)(c) of the Income Tax Act and relied on exemption certificates issued under Section 136(5)(b).

However, the tax authority maintained that once the produce is imported for commercial resale, it remains subject to taxation at the point of entry.