On 12th August 2025, the Tax Appeals Tribunal (TAT) handed down a landmark decision in Africa Global Logistics Uganda Ltd v URA, a case that places timelines and jurisdictional clarity at the very center of Uganda’s tax dispute framework. The ruling reinforces one timeless truth in tax law: procedure is not a technicality, it’s the backbone of justice.
The dispute began with an objection decision issued by URA on 13th April 2024. The taxpayer, dissatisfied, opted to pursue ADR, a mechanism designed to encourage settlement without lengthy litigation. URA’s ADR committee eventually issued its decision on 19th April 2024, maintaining the tax liability in full. Believing this outcome to be a fresh tax decision in itself, the taxpayer proceeded to file an application before the Tribunal on 16th May 2024. URA, however, swiftly objected, arguing that the filing was hopelessly out of time and legally defective. From URA’s perspective, the 30-day statutory clock to file before TAT had begun ticking from the date of the objection decision in April not from the ADR outcome that followed. This set the stage for a legal battle that raised profound questions about the relationship between ADR, statutory timelines, and appellate jurisdiction.
In its detailed ruling, the Tribunal agreed with URA’s position and dismissed the taxpayer’s application. The decision is striking in its clarity. First, TAT held that ADR decisions do not constitute taxation decisions capable of being challenged before it. Section 14(1) of the TAT Act, enacted in 1998, confers appellate jurisdiction only with respect to decisions of the Commissioner General of URA, not those of an ADR committee. To stretch this provision to cover ADR outcomes would, in the Tribunal’s view, amount to creating jurisdiction where Parliament has not expressly provided it. In matters of jurisdiction, the Tribunal emphasized, silence cannot be interpreted as permission.
Secondly, the Tribunal addressed the contentious issue of timelines. It held emphatically that the 30-day window within which to file an application to TAT is unaffected by ADR proceedings. ADR, though encouraged as a mechanism for settlement, does not suspend, extend, or reset statutory deadlines. Once the objection decision is communicated, the countdown begins, and nothing short of legislative amendment can change that. By majority, the Tribunal also found that while ADR outcomes may be framed in the language of liability, they remain administrative in nature and cannot be elevated to the status of tax decisions under the law.
This ruling carries weighty implications for both taxpayers and the revenue authority. For taxpayers, it is a sobering lesson in vigilance: timelines in tax law are unforgiving, and no amount of equitable argument can substitute for strict statutory compliance. Filing late, even in the genuine belief that ADR extended the deadline, is fatal. Legal advisors must now pay closer attention to procedural clocks, treating the objection decision as the definitive marker for appeal windows, irrespective of whether ADR is ongoing. For URA, the Tribunal’s rebuke regarding delays in ADR highlights the urgent need for efficiency and transparency. An ADR decision rendered more than eleven months after the objection was hardly a showcase of timeliness, and while the Tribunal refused to let URA’s shortcomings rewrite the law, it noted that such administrative inertia undermines taxpayer confidence in the system.
The broader tax community must also reflect on the delicate balance this ruling exposes. ADR was introduced through the Tax Procedure Code Act of 2016 as a progressive innovation to decongest the Tribunal and foster consensual resolution of disputes. Yet, if its outcomes cannot be reviewed and if participation in ADR does not affect statutory deadlines, its utility risks being questioned. Parliament may, in the future, need to clarify whether ADR should feed into, or stand entirely apart from, the appellate system. Until such clarity arrives, taxpayers must view ADR as a parallel track for settlement, not as a procedural shield.
What emerges unmistakably from this case is a reaffirmation of the sanctity of statutory procedure. The Tribunal has reminded us that in tax disputes, justice does not bend to convenience. Deadlines are not soft suggestions but substantive rules, and jurisdiction cannot be implied but must be conferred in black-letter law. The echoes of the High Court’s earlier decision in CIC Africa (U) Ltd v URA resound strongly here: ADR outcomes are final within URA, and TAT remains bound by statutory limits.
The Africa Global Logistics case is a cautionary tale. It tells businesses and practitioners alike that while fairness and efficiency are desirable, the surest safeguard in tax litigation is precision in following the law. The Tribunal’s message could not be clearer: ADR is a settlement tool, not an appeal route; timelines are strict, not elastic; and appellate jurisdiction must be written into statute, not inferred by implication.
Taxpayers who miss the 30-day filing window cannot seek refuge in ADR outcomes, however delayed or unsatisfactory they may be. By upholding the supremacy of statutory procedure over administrative processes, the Tribunal has reaffirmed a fundamental truth in “tax disputes, justice is not only about fairness, it is first and foremost about compliance with the law”.
The writer is a chartered Accountant, Tax Analyst and Advisor
