Uganda’s Tax Appeals Tribunal has reinforced the importance of statutory time limits in tax disputes, ruling that an objection decision issued after the prescribed 90-day period was null and void.
For taxpayers facing an assessment from a revenue authority, procedural deadlines can be just as important as the underlying tax liability.
A recent decision of the Uganda Tax Appeals Tribunal in Munyanga Development Limited v Uganda Revenue Authority (TAT Application No. 73 of 2026), delivered on 30 June 2026, illustrates this point clearly.
The Tribunal held that where the Uganda Revenue Authority (“URA”) fails to issue an objection decision within the statutory 90-day period, and the taxpayer validly elects to have the objection treated as allowed, the objection is resolved by operation of law. A subsequent objection decision issued by the URA is therefore null and void.
The Background
Munyanga Development Limited operates a tourist accommodation business under the name Mahogany Springs Luxury Resort in Kihihi, Kanungu District.
On 22 November 2025, the URA issued a tax assessment of UGX 2.6 billion for the 2022 to 2024 period. The assessment arose because the revenue reported in the company’s audited financial statements did not correspond with credits appearing in its bank statements.
The taxpayer objected to UGX 2.45 billion of the assessment on 31 December 2025.
The parties subsequently engaged on the objection, with the taxpayer providing various documents to the URA during meetings and engagements held in February and March 2026.
The URA ultimately issued an objection decision partially allowing the objection by UGX 792.2 million, while disallowing the remaining UGX 1.81 billion.
There was, however, a timing issue.
The 90-Day Deadline
Under section 26 of Uganda’s Tax Procedures Code Act, the URA is required to serve an objection decision within 90 days from the date of receipt of the objection, subject to the applicable provisions concerning extension or waiver.
The taxpayer lodged its objection on 31 December 2025.
On 31 March 2026, the taxpayer issued an election notice seeking to have the objection treated as allowed.
The central question was therefore whether the statutory 90-day period had already expired.
The Tribunal concluded that it had.
In interpreting the statutory wording, the Tribunal considered the meaning of the word “from”, finding that it identifies the point at which the relevant period starts. On that basis, the Tribunal determined that the 90-day period expired on 30 March 2026.
The taxpayer’s election notice on 31 March was therefore lodged on the 91st day.
What Happens When the Tax Authority Misses the Deadline?
This was the key issue in the case.
The Tribunal considered sections 26(6), 26(7) and 26(8) of the Tax Procedures Code Act. It held that once the taxpayer validly lodged its election after the expiry of the 90-day period, the objection was deemed to have been allowed.
Importantly, this consequence arose automatically by operation of law. It did not require approval from the Commissioner General.
The Tribunal therefore found that, once the election notice was lodged on 31 March 2026, the objection had been conclusively resolved in the taxpayer’s favour.
The URA no longer had jurisdiction to issue, vary or supplement an objection decision relating to the same objection.
The subsequent URA objection decision was consequently declared null, void and unenforceable.
The additional assessment of UGX 1.81 billion was also declared void and unenforceable, with costs awarded to the taxpayer.
What About the Ongoing Engagements?
One potentially important aspect of the case is that the parties had continued engaging during the 90-day period.
The taxpayer had provided additional documentation to the URA during meetings on 5 February, 16 March and 19 March 2026.
However, the Tribunal noted that there was no evidence that the URA had formally notified the taxpayer that the 90-day period had been waived or extended under section 26(9), or that further documents were required before an objection decision could be issued.
The existence of ongoing discussions therefore did not, on the facts before the Tribunal, prevent the statutory period from expiring.
This is an important practical point. Informal engagement between a taxpayer and a revenue authority should not necessarily be assumed to suspend or extend a statutory deadline.
Where legislation provides a specific mechanism for extending or waiving a deadline, taxpayers and tax authorities need to understand and follow that mechanism.
Why Does This Matter for Taxpayers?
The decision is relevant beyond the particular facts of the case because it demonstrates the practical importance of procedural rights in tax administration.
Tax disputes often focus heavily on the substantive question: Does the taxpayer actually owe the tax?
But before reaching that question, there may be a series of procedural requirements governing:
- when an assessment may be issued;
- when a taxpayer must object;
- when the revenue authority must respond;
- whether extensions are permitted;
- when an objection is deemed to have been allowed;
- when an appeal may be lodged; and
- what happens when a statutory deadline is missed.
These requirements can have material consequences for both taxpayers and revenue authorities.
In the Munyanga case, the Tribunal’s finding meant that a significant portion of the disputed assessment could not be enforced because of the URA’s failure to comply with the applicable statutory timeline.
Time Limits Work Both Ways
The broader lesson is that statutory deadlines are not simply administrative targets.
Where legislation establishes a specific timeframe and attaches legal consequences to the failure to comply with it, those provisions can materially affect the outcome of a tax dispute.
For taxpayers, this means that objection and appeal deadlines should be actively monitored rather than treated as administrative formalities.
For revenue authorities, the case demonstrates the importance of having systems in place to monitor statutory deadlines and ensure that decisions are issued within the required periods.
It also highlights the importance of formally documenting any agreed extension, waiver or request for additional information where the legislation provides for one.
A Wider African Tax Administration Lesson
The Uganda decision also raises a broader issue for tax administration across Africa.
As revenue authorities strengthen enforcement and increasingly rely on formal dispute processes, taxpayers need to understand not only their substantive tax obligations but also their procedural rights.
Where legislation gives taxpayers a specific protection against administrative delay, those protections can be meaningful.
The practical lesson is therefore straightforward: know the deadline, know what happens when it expires, and keep a clear record of every step in the dispute process.
Taxpayers should not assume that continued discussions with a revenue authority automatically stop the statutory clock. Equally, tax authorities need to ensure that procedural requirements are followed if their decisions are to remain enforceable.
The Munyanga decision is a useful reminder that, in tax disputes, timing is not merely procedural, it can determine whether a tax decision is legally effective.
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