Taxation law

Total Uganda Limited v Uganda Revenue Authority (Civil Appeal No. 1 of 2002 ) [2002] UGCA 2 (22 April 2002);


Search Summary: 

The Uganda investment Authority issued a certificate of incentive to no-
resident shareholders in the appellant company exempting them from
corporation tax, tax on dividends and withholding tax for five years. The
law under which the certificate was granted was repealed by parliament by
the holder an option to apply to the commissioner general of the
respondent for the continuation of the privilege paid to resident persons
whom the appellant fulfilled.

Headnote and Holding: 

whom the appellant fulfilled.
The crux of the appeal was whether the amendment related to exemption
from withholding tax on dividends paid to residents’ shareholders only or
to both resident and nonresident and the court observed that the word
“exemption” applied only to corporate profits and withholding tax on
dividends and interest to resident persons were exempted.
The appeal was dismissed.


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