TASLAF Legal Alert: Tribunal limits Uganda's 30% interest deductions rule.

Greetings from TASLAF Advocates!

We are pleased to share our latest Legal Alert analysing the recent Tax Appeals Tribunal decision in Techno Three Uganda Limited v Uganda Revenue Authority.

The Tribunal ruled that companies with dormant group affiliates may not be subject to the restrictive 30% EBITDA interest deduction cap. This decision applies a substance-over-form approach that prioritises the economic reality of group structures over technical ownership.

This ruling provides important guidance on interest deductibility, base erosion considerations, and strategic tax planning for businesses operating within group structures.

Please find the detailed alert attached for your review. If you require any assistance assessing the implications of this decision, reviewing your group structure, or addressing tax compliance matters, our Tax and Legal Team will be pleased to support you.

For more information, visit TASLAF Advocates.