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In this issue:
Tax Alert - Tax Appeals Tribunal clarifies the 90-Day rule for URA objection decisions
The Munyanga Tribunal Decision
On 30 June 2026, the Tax Appeals Tribunal ruled that Munyanga Development Limited validly elected to treat its objection as allowed after the Uganda Revenue Authority (“URA”) failed to serve its objection decision within the statutory 90-day period, rendering URA’s later decision after the election null, void and unenforceable.
Introduction
Munyanga Development Limited, trading as Mahogany Springs Luxury Resort in Kihihi, Kanungu District, is engaged in the business of tourist accommodation. On 22 November 2025, URA issued an additional income tax assessment for the period 2022 to 2024 on the basis that the revenue reported in the taxpayer’s audited financial statements did not match the credits reflected on its bank statements.
On 31 December 2025, Munyanga objected to tax amounting to UGX 2,451,456,441. On 31 March 2026, Munyanga lodged issued an election notice under Sections 26(6) and 26(7) of the TPCA to treat the objection as allowed, on the basis that URA had not served an objection decision within the prescribed 90-day statutory period.
On 31 March 2026, after Munyanga objected had lodged its election, URA issued an objection decision partially allowing the objection in the sum of UGX 792,248,194 and disallowing the objection in the sum of UGX 1,808,625,194. URA also issued an election rejection notice on the same day.
Please find our latest alert for further insights.
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