URA WINS SHS205M TAX BATTLE! Goodways Trustees Loses Appeal Over Makerere Land
URA CG Rujoki
KAMPALA — Uganda Revenue Authority (URA) has scored a major victory in a long-running tax dispute after the Court of Appeal dismissed an appeal by Goodways Trustees Limited, leaving the company liable for Shs205.1 million in unpaid taxes and exposing its Makerere property to possible sale.
In a judgment delivered in Kampala on October 12, 2026, Deputy Chief Justice Moses Kazibwe Kawumi upheld an earlier High Court decision allowing URA to recover the outstanding taxes through land comprised in Kibuga Block 28 Plot 334.
The appellate court also ordered Goodways Trustees to pay the costs of the proceedings in both the Court of Appeal and the High Court.
The dispute dates back several years when URA demanded Shs502,029,354 in unpaid corporation tax, including assessments and interest relating to the period between 1996 and 2004.
After repeated demands for payment allegedly went unanswered, URA registered a charge against the company’s property as security for the outstanding tax.
Goodways disputed the assessment, insisting that an audit of its financial records had established that its tax liability was only Shs4.6 million.
The company further argued that correspondence forwarding its audited accounts to URA amounted to a valid objection to the tax assessment.
It also contended that URA’s withdrawal of a warrant of distress had effectively brought the enforcement process to an end and reopened the matter for review.
However, URA maintained that although the Finance Act 2008 waived income tax arrears outstanding before July 1, 2002, Goodways still owed Shs205,127,100 for the period between August 1, 2002 and December 30, 2004.
The High Court agreed with URA and gave the company six months to settle the outstanding amount, warning that failure to pay would result in the property being sold through private treaty.
Goodways subsequently appealed, challenging the findings and arguing that the tax authority had failed to properly consider its audited accounts and earlier correspondence.
But Justice Kawumi dismissed the arguments, pointing to documentary evidence showing that URA withdrew the warrant of distress on November 7, 2006, before Goodways filed its audited financial statements on November 15, 2006.
He consequently rejected the company’s suggestion that the withdrawal of the warrant had resulted from an objection based on the audited accounts.
“The letter withdrawing the Warrant of Distress from M/S Kamugasha Agencies attached as evidence for the appellant is dated November 7, 2006,” the judge observed, adding that the withdrawal could not have resulted from audited statements that were filed eight days later.
The judge further noted that the audited accounts covered only one financial year and did not address the entire period for which URA had raised the tax assessment.
He also rejected the argument that withdrawing the warrant of distress automatically extinguished the charge registered against the property.
“The record shows that after continuous reminders, a charge was lawfully placed on the appellant’s property as security for unpaid tax. The assertion that the charge collapsed upon the withdrawal of the warrant of distress is not plausible. The charge could only be removed upon payment of the taxes due,” Justice Kawumi ruled.
The court stressed that statutory deadlines for challenging tax assessments are legal requirements and cannot be dismissed as mere technicalities.
Since Goodways had failed to lodge a formal objection within the period prescribed under the Income Tax Act, it could not reopen the assessment through subsequent correspondence or the submission of audited accounts.
Justice Kawumi consequently upheld the Shs205,127,100 outstanding tax liability, which remained payable after the statutory waiver of earlier arrears.
The Court of Appeal unanimously dismissed the appeal, handing URA another victory in its efforts to recover outstanding taxes.
Goodways now faces the obligation to settle the Shs205.1 million tax liability, with its Makerere property remaining subject to the recovery process outlined by the High Court.
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