Uganda Cross-Border Taxation Guide 2026

Cross-border taxation in Uganda involves withholding taxes on payments to non-residents, transfer pricing rules for related-party transactions, and a network of over 15 Double Taxation Treaties. URA has increased its focus on cross-border tax compliance and transfer pricing audits.

Withholding Taxes on Payments to Non-Residents

Uganda imposes withholding tax on various payments to non-residents. The standard rates are:

Dividends: 15%
Interest: 15%
Royalties: 15%
Management fees: 15%
Rental income: 15%
Service fees: 15% (for certain technical services)

These rates may be reduced under applicable Double Taxation Treaties. The payer must withhold the tax and remit it to URA by the 15th of the following month.

Transfer Pricing

Uganda has transfer pricing rules based on the OECD Transfer Pricing Guidelines. Related-party transactions must be conducted at arm's length prices. Taxpayers with related-party transactions exceeding UGX 500 million must maintain transfer pricing documentation. URA has increased transfer pricing audits in recent years, particularly for management fees, royalties, and intercompany financing.

Double Taxation Treaties

Uganda has over 15 Double Taxation Treaties in force, including with the UK, South Africa, India, Kenya, Mauritius, Netherlands, Denmark, Norway, and others. Treaty relief is available on application to URA and typically requires a certificate of tax residence from the treaty partner.

Permanent Establishment Risk

Non-resident companies operating in Uganda risk creating a permanent establishment (PE) through a fixed place of business, a construction site exceeding 6 months, or a dependent agent. PE income is taxed at 30%.

Disclaimer

This guide provides general information. Tax laws may change. Consult a qualified Ugandan tax advisor or URA for your specific situation.