Court dismisses Nile Breweries Ltd case against Uganda Revenue Authority

KAMPALA - The Commercial Division of the High Court has dismissed an application filed by Nile Breweries Limited seeking an injunction to block the Uganda Revenue Authority (URA) from recovering sh18 billion in taxes.

Nile Breweries Limited had asked the court to stop URA from enforcing an order issued by the Tax Appeals Tribunal, which found the company liable for Value Added Tax (VAT) and Local Excise Duty amounting to sh18 billion.

Justice Susan Odongo on May 25, 2026, dismissed the application, upheld the decision of the Tax Appeals Tribunal, and ordered Nile Breweries Limited to pay costs to URA.
Nile Breweries Limited is a manufacturer of alcoholic beverages and also exports its products to regional markets, including South Sudan and the Democratic Republic of Congo.

According to court document Nile Breweries Limited formally objected to the tax assessments on March 22, 2024. However, URA issued objection decisions on April 30 and June 11, 2024, dismissing the objections and upholding the assessments.

Nile Breweries Limited subsequently filed an appeal at the Tax Appeals Tribunal (TAT) Application. In its ruling delivered on November 21, 2025, the Tribunal struck out some of the assessments on grounds that they were time-barred but upheld Nile Breweries Limited’s liability for Value Added Tax (VAT) and Local Excise Duty (LED) amounting to 18,509,052,729.

The Tribunal found that the transactions in question constituted local taxable supplies.

According to an affidavit in support of the application by Faith Mirembe, the Legal and Compliance Manager and Company Secretary of Nile Breweries Limited, had argued that there is an imminent threat if URA executes, adding that URA intends to issue agency notices to Nile Breweries Limited’s bankers to recover the full disputed amount.

Nile Breweries Limited argued that allowing the recovery process of the money to proceed while there is an appeal still pending would render the process void and place it in an untenable position.

It is further contended that the status quo should be preserved to ensure that, in the event of a successful appeal, the outcome is not rendered void.

“This court must also guard against the abuse of process; allowing litigants to file repetitive applications after a set period would lead to judicial chaos and would undermine the authority of final court orders.

A taxpayer could, in theory, file a stay of execution, then a temporal injunction, then an interim stay, and then a constitutional stay, all targeting the same assessment, effectively paralysing the Revenue Authority’s ability to fulfil its public duty,” Justice Odongo said.