We provide a wealth of publications by PwC Uganda providing informed commentary on current developments in the tax and legal arena, both locally and internationally.
Through analysis and comment on new law and judicial decisions of interest, they assist business executives to identify developments and trends in tax law and revenue practice that might impact their business.
Tax Alert - High Court reinforces purpose-based approach to interest deductions
On 30 March 2026, the High Court (Commercial Division) clarified the deductibility of interest under section 25(3) of the Income Tax Act in respect to a “group”. Court held that the 30% EBITDA interest limitation is not intended to apply to all taxpayers in a group of companies irrespective of the loan circumstances. Consequently, the Court set aside the decision of the Tax Appeals Tribunal which had held that common underlying ownership alone was sufficient to trigger the 30% EBITDA interest limitation.