The High Court in Kampala has upheld a tax assessment of Shs1,091,541,475 against Airtel Uganda Limited, ruling that the telecommunications company is liable to pay the amount following a dispute with the Uganda Revenue Authority over the valuation of imported equipment.
In a judgment delivered on April 22, 2026, Justice Stephen Mubiru found that URA acted within the law when it rejected Airtel’s declared import values and applied an alternative method of assessing tax based on identical goods.
“The respondent was justified, on the facts of the case, to depart from the transaction value method and instead apply the transaction value of identical goods,” Justice Mubiru ruled.
The case arises from Airtel Uganda’s 2018 importation of a Broadband Processing Board from China, which it declared at a unit price of about 1,349 dollars. However, URA established that another telecommunications company had imported similar equipment from the same manufacturer at a much higher price of over 10,000 dollars per unit.
The significant price difference prompted URA to conduct a customs audit and request further documentation from Airtel to justify the declared value. Among the documents requested were details of pricing negotiations, discount arrangements and proof that such discounts were available under normal commercial conditions.
Court records show that Airtel did not provide the additional information despite being given time, raising doubts about the accuracy of its declared value.
“The appellant failed to demonstrate how it arrived at the invoiced unit price,” the judge observed.
He noted that this failure justified URA’s decision to question the transaction value.
URA then applied the method of valuation based on identical goods and issued an additional tax assessment of more than Shs 1.09 billion.
Airtel challenged the decision before the Tax Appeals Tribunal, arguing that it had provided sufficient documentation including purchase orders and invoices. The Tribunal, however, did not make a final determination and instead directed further inquiries, including verification of the equipment and confirmation of prices from another importer.
The High Court disagreed with that approach and found that the Tribunal erred in law by failing to resolve the matter on the available evidence.
“The Tribunal misdirected itself when it ordered further verification despite sufficient material on record,” Justice Mubiru stated.
The court also rejected Airtel’s attempt to introduce new evidence at the appeal stage, including a receipt that had not been presented earlier.
“A party who has been unsuccessful at the trial must not seek to adduce additional evidence to fill up omissions or patch up weak parts of their case,” the judge ruled.
On the question of valuation, the court agreed with URA that the imported equipment qualified as identical goods, noting that both sets were produced by the same manufacturer, around the same time, and had the same technical characteristics and function.
“There is no evidence showing any difference in brand, physical characteristics, quality or functionality,” the judgment states.
Justice Mubiru further noted that the large price gap, combined with the lack of supporting documentation, provided sufficient grounds for URA to reject the declared value and apply an alternative method of assessment.
The court ultimately held that while Airtel succeeded on a legal point regarding the Tribunal’s handling of the case, the tax liability itself remained valid and enforceable, with each party ordered to bear its own legal costs.
