Tax disputes in Uganda are won and lost on the calendar as much as on the merits. The law gives a taxpayer real avenues to challenge an assessment, but each avenue closes on a fixed date, and an objection filed late is, in most cases, no objection at all.
The 45-day objection window
Under the Tax Procedures Code Act, a taxpayer dissatisfied with an assessment must lodge a written objection with URA within 45 days of receiving the notice of assessment. The objection must state the grounds precisely. An objection that simply says “we disagree” preserves nothing. Grounds not raised at objection are difficult to introduce later, so the objection is not a formality; it is the foundation of the whole dispute.
What URA must do, and what silence means
URA is required to make an objection decision within 90 days. If it does not, the taxpayer may treat the objection as allowed, but this must be actively invoked, not assumed. Diarise the 90th day and take advice on the position when it passes.
The 30-day appeal to TAT
If the objection decision goes against you, an application to the Tax Appeals Tribunal must be lodged within 30 days of being served with that decision. Note the pay-to-play rule: as a general condition, the taxpayer must pay 30% of the tax in dispute (or the undisputed portion, whichever is greater) pending the appeal. This figure shapes strategy. Sometimes the commercially sound move is a settlement conversation with URA before positions harden.
Interest does not wait
Interest continues to accrue on unpaid tax while the dispute runs. A taxpayer who is confident on some heads of an assessment but weak on others should consider paying the weak heads early and fighting the strong ones. Disputes are rarely all-or-nothing.
The better dispute is the one you avoid
Most assessments we contest trace back to gaps that predate the audit: undocumented related-party transactions, unfiled returns, or record-keeping that cannot support declared figures. Proactive structuring and compliance reviews cost a fraction of a contested assessment, and they leave you with a file that wins objections quickly when they do arise.
