Uganda court allows tax authority to collect $5 million from Nile Breweries

The Commercial Division of the High Court has rejected Nile Breweries Uganda Limited's attempt to halt the collection of 18.5 billion Shillings in disputed taxes by the Uganda Revenue Authority (URA).

The High Court's decision, delivered by Justice Odongo, dismissed Nile Breweries' application seeking to prevent the URA from enforcing the tax demand. The court found that the company was trying to re-argue issues that had already been definitively settled by a competent court.

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Nile Breweries was attempting to relitigate an issue that had already been conclusively determined by a court of competent jurisdiction and that allowing the new application to proceed would amount to revisiting issues that had already been decided.

The tax dispute centers on Value Added Tax (VAT) and Local Excise Duty for the period between January and November 2022. The URA reassessed the company, determining that Nile Breweries owed over 18.5 billion Shillings. The brewery, which produces alcoholic beverages and exports to South Sudan and the Democratic Republic of Congo, maintained that the goods were intended for export and thus exempt under Uganda's zero-rated export regime. However, the URA's assessment concluded that the products were not manufactured for export and were subject to taxation.

Nile Breweries had previously taken the matter to the Tax Appeals Tribunal, which ruled in favor of the URA. Following this, the company appealed to the High Court. Before the appeal could be heard, Nile Breweries filed an application in March 2026 seeking interim protection to stop URA's enforcement actions. This application was dismissed by Justice Abinyo. Subsequently, the company filed another application to stay the execution of the Tax Appeals Tribunal's order, which was also dismissed by Justice Odongo. The judge emphasized that allowing the second application would mean revisiting matters already decided, as the substance of both applications was the same: whether URA should be restrained from collecting the 18.5 billion Shillings.

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although Nile Breweries argued that there was a distinction between a stay of execution and a temporary injunction, the substance of the issue remained the same, whether URA should be stopped from collecting the 18.5 billion shillings.