Tax and private wealth

URA Audit Defence & Assessment Objections

• Representation during tax audits and desk reviews
• Drafting and filing formal objections under Section 99 of the Tax Procedures Code
• Requests for clarification or remission of penalties and interest
• Review of URA computation methodology and legal basis
• Carry out negotiations with URA to ensure amicable settlement of tax controversy

Tax Appeals Tribunal Representation

• Preparation of appeals and pleadings before the TAT
• Managing disclosure, expert evidence, and legal submissions
• Negotiation of settlements or withdrawal of invalid assessments
• Procedural and jurisdictional challenges

High Court & Appellate Tax Litigation

• Appeals from the Tax Appeals Tribunal
• Judicial review of URA decisions
• Constitutional tax litigation
• Strategic litigation in precedent-setting cases

Alternative Dispute Resolution (ADR) with URA

• Applying for and managing tax ADR
• Engaging URA’s Legal and ADR departments
• Negotiating payment plans and compromise settlements
• Ensuring confidentiality and enforceability of agreements

Tax Penalty Mitigation & Recovery

• Applications for waiver of penalties and interest
• Recovery of overpaid or wrongly assessed taxes
• Legal action to lift garnishee orders or freeze directives
• Defence against criminal tax sanctions

Tax Compliance & Advisory

• Interpretation of Uganda tax laws and statutory obligations
• Tax health checks and risk reviews
• Tax structuring for business transactions
• Sector-specific tax planning (telecom, banking, agriculture, etc.)
• Guidance on tax treatment of employment, benefits, and expatriates
• Settlement negotiations with URA legal and audit teams

Corporate & Transactional Tax

• Tax advisory on business setup and structuring in Uganda
• Mergers, acquisitions, and reorganizations
• Tax-efficient real estate and land transactions
• Stamp duty planning
• VAT implications on domestic and cross-border supplies

Withholding & Payroll Taxes

• PAYE compliance advisory
• Taxation of allowances, pensions, and benefits in kind
• Withholding tax on payments to residents and non-residents
• Annual returns and reconciliations with URA

Tax Incentives & Exemptions

• Guidance on tax incentives under the Income Tax and VAT Acts
• Sector-specific exemptions (education, agriculture, exports)
• Uganda Investment Authority (UIA) certification support
• Tax structuring for donor-funded or exempt projects

International Corporate Tax Advisory

• Cross-border tax structuring
• Jurisdictional comparisons for holding companies
• Permanent establishment risk management
• Tax-efficient repatriation strategies
• Group reorganizations and M&A tax planning
• Holding and operating structure planning
• Treaty structuring and interpretation
• Global tax compliance (FATCA, CRS, BEPS)
• Permanent establishment risk assessment

Transfer Pricing

We bring together legal, tax, and commercial insight to help clients structure intra-group transactions, mitigate double taxation, and respond to the growing scrutiny of cross-border trade.

Transfer Pricing services include:

• Transfer Pricing Advisory & Documentation
• Design of TP policies and intra-group pricing models
• Preparation of Local Files and Master Files
• Benchmarking and economic analysis
• Intercompany agreement review and drafting
• Functional and risk profiling of group entities

Audit Defense & Dispute Resolution

• Response to TP audits by Uganda Revenue Authority (URA)
• Objections and appeals under the Tax Procedures Code
• MAPs (Mutual Agreement Procedures) and APA advisory
• Dispute resolution and litigation before the Tax Appeals Tribunal
• Double tax relief and competent authority procedures

Transaction Structuring & Risk Mitigation

• Legal input into cross-border financing and royalties
• IP structuring and licensing strategy
• TP implications of supply chain, services, and management fees
• Exit charges and business restructuring guidance
• Thin capitalization and debt pricing review

Compliance & Regulatory Engagement

• TP compliance reviews and legal risk audits
• Country-by-Country Reporting (CbCR) coordination
• Support with URA disclosures and documentation deadlines
• Engagement with revenue authorities on advance rulings and clarifications

Tax Treaty Advisory

• Application and interpretation of DTAs
• Residency planning and treaty override risk
• Withholding tax optimization
• Anti-abuse provisions and limitation of benefits
• Treaty shopping risk mitigation

Compliance & Reporting

• Global tax reporting and disclosures
• Economic substance
• Exit tax and expatriation tax planning
• Global mobility and employment tax

Private Wealth & Trust Planning

Estate & Succession Planning

• Wills and living Wills
• Trust creation (family, charitable, offshore)
• Letters of wishes and family protocols
• Probate and estate administration
• Planning for incapacity and guardianship

Family Trusts & Asset Protection

• Revocable and irrevocable trusts
• Private trust companies (PTCs)
• Business asset protection structures
• Divorce-proofing and intergenerational asset safeguards
• Wealth preservation in volatile jurisdictions

Cross-Border Wealth Planning

• Structuring for foreign assets and dual residency
• Inheritance planning for global families
• FATCA, CRS, and tax reporting compliance
• Working with offshore trustees and corporate service providers
• Repatriation and investment exit planning

Family-Owned Business Advisory

• Succession planning for business-owning families
• Shareholder and family governance agreements
• Board and next-gen leadership advisory
• Conflict avoidance and intergenerational transition
• Philanthropy structuring and family foundations

Private Investment & Holding Structures

• • Holding companies for real estate, equity, and private investments
  • Offshore and regional investment vehicles
  • Co-investment and partnership agreements
  • Tax efficiency and risk mitigation structures
  • Legal support for UHNW investment platforms