Kampala tribunal drops Shs 1.35 billion VAT bomb on Shoprite

Uganda's Tax Appeals Tribunal ordered Shoprite Checkers Limited to pay 1,354,624,690 shillings in Value Added Tax to the Uganda Revenue Authority. The ruling emerged from a lengthy dispute regarding undeclared sales during the 2016 and 2017 financial years. Tribunal Chair Siraj Ali led a three-member panel that rejected the retailer's defense arguments. The decision requires both parties to reconcile a separate Pay-As-You-Earn liability worth 58.9 million shillings by July 15, 2025. URA received three-quarters of the application costs under the tribunal's final judgment.

The revenue authority discovered discrepancies between Shoprite's reported VAT sales figures and calculations used for franchise fee payments. Shoprite claimed the differences resulted from inter-divisional transfers between its Freshmark Division and Supermarket Division involving unprocessed agricultural products. The tribunal found that transferred items contained standard-rated processed goods subject to VAT obligations. Sample invoices revealed taxable products such as Snack Mixes and Dried Fruit Flakes among the disputed transfers. The panel dismissed Shoprite's explanation about accounting errors following a finance manager's departure as implausible given corporate control standards.

The Pay-As-You-Earn dispute centers on taxable benefits provided to expatriate employees. These benefits encompassed rent payments, school fees, and utility expenses for foreign staff members. Both parties acknowledged the taxable nature of these sundry benefits during proceedings. Shoprite maintained it had already addressed these tax obligations through proper accounting procedures. The multinational retailer exited Uganda's retail market in 2021 but remains responsible for audit findings and tax liabilities from its operational period.
 

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