Grant Thornton is a global network of 76,000 people in member firms in 156 markets, with one common goal — to help you realise your ambitions. Our member...
Whether you’re growing in one market or many, looking to operate more effectively, managing risk and regulation, or realising stakeholder value, our firms can help.
In a world that wants more options for high quality services, we differentiate in the market to grow sustainably in today’s rapidly changing environment.
Grant Thornton International Ltd acts as the coordinating entity for member firms in the network with a focus on areas such as strategy, risk, quality monitoring and brand.
The global leadership team (GLT), chaired by the GTIL CEO is a full-time management group dedicated to leading the network in the successful execution of the...
The relationship between a company and its auditor has changed. Organisations must understand and manage risk and seek an appropriate balance between risk and opportunities.
At Grant Thornton, we have a wealth of knowledge in forensic services and can support you with issues such as dispute resolution, fraud and insurance claims.
We work with entrepreneurial businesses in the mid-market to help them assess the true commercial potential of their planned acquisition and understand how the purchase might serve their longer-term strategic goals.
We can support you throughout the transaction process – helping achieve the best possible outcome at the point of the transaction and in the longer term.
We can assist you with a variety of sustainability advice depending on your needs, ranging from initial strategy development, reporting and compliance support, through to carbon measurement and management.
Our services can strengthen your business and stakeholders' confidence. You'll receive professionally verified results and insights that help you grow.
Our global assurance technology platform provides the ability to conduct client acceptance, consultations and all assurance and other attestation engagements.
Our sustainability assurance services are based on our global network of specialists, helping you make more efficient decisions for the good of your organisation.
Through our global organisation of member firms, we support both companies and individuals, providing insightful solutions to minimise the tax burden for both parties.
Using our finely tuned local knowledge, teams from our global organisation of member firms help you understand and comply with often complex and time-consuming regulations.
The laws surrounding transfer pricing are becoming ever more complex, as tax affairs of multinational companies are facing scrutiny from media, regulators and the public
Through our sustainability tax advisory services, we can advise how environmental taxes, incentives, and obligations can impact your progress, requiring alignment with governmental and legislative pressures.
We offer an extensive range of services to automotive sector stakeholders from supply chain through to distribution, retail and usership. With a variety of...
History has something important to tell us about the difficulties of steering a business to long-term success – through seismic shifts in technology, consumer demands and product development. With that in mind it’s unsurprising that over half the world’s largest companies in the early 1900s had shut their doors by the late 1990s. Some, however, have endured.
Following world events such as the COVID-19 pandemic, Brexit, and changes to regulation and digitalisation, insurers must be alert to the challenges ahead.
We help businesses navigate today’s changing private equity landscape, ensuring that you can respond to ever-changing regulations and investor demands.
When the global COVID-19 pandemic stormed across the globe in early 2020, the private equity sector was hit hard but deals are coming back to the market.
Nervous about partnering with Private Equity? We explore some of the common myths we come across when speaking to mid-market businesses about PE investment.
Jessica Patel, Tax Partner at Grant Thornton UK speaks with tax partners and directors across the network to share their insights on the real estate market and some of the challenges.
Jessica Patel, Tax Partner at Grant Thornton UK speaks with tax partners and directors across the network to share their insights on the real estate market and some of the challenges.
The past two years saw the retail industry experience significant disruption, however there will still be opportunities to effectively reposition for future...
Businesses are seeing rising challenges, and finance heads are dealing with a range of new measures. To say the next 12 months are critical for businesses is an understatement.
In this article, we’ve summarised key elements of the global tax reform proposals, their potential impact on technology industry and advice from our digital tax specialists on what technology companies can do to prepare.
Our research revealed five key trends that resonated with Technology, Media and Telecoms (TMT) industry leaders around the world. We asked a panel of our experts from UK, US, India Ireland and Germany, to give us their reaction to the findings.
Our research revealed five key trends that resonated with Technology, Media and Telecoms (TMT) industry leaders around the world. We asked a panel of our experts from UK, US, India Ireland and Germany, to give us their reaction to the findings.
Technology companies must adopt a new approach to digital risk: those that successfully develop a reputation for digital trust by demonstrating an unwavering commitment to cyber security and data privacy will be able to carve out a competitive advantage.
Figures suggest the mobile sector is maturing. While data usage continues to soar, mobile revenues are expected to flatten out over the next few years.
The COVID-19 pandemic caused unprecedented levels of disruption to the global travel industry. As this evolves, it is unclear what recovery looks like.
Optimism among global mid-market business leaders rose to 67% in the first half of this year and they are markedly more optimistic about their prospects with global optimism having increased by 8%.
For 21 years, the Women in Business report has tracked the proportion of women in senior roles in the mid-market. Progress has been made but with gender equity over 25 years away, that isn’t soon enough.
Mid-market firms are scaling sustainability for growth, not just compliance. Grant Thornton’s International Business Report (IBR) 2025 report reveals how sustainability investments are driving profitability, resilience and global expansion — despite regulatory shifts and political uncertainty.
A shifting global trade landscape is contributing to rising uncertainty, but could it also unlock new opportunites for adaptable mid-market businesses while larger companies opt to wait and see?
Women holding the CFO role is nearing parity – reshaping finance leadership and potentially helping increase female representation across all senior roles.
With seismic shifts in the global landscape, leaders must take deliberate action to propel their businesses into a more inclusive future, foster innovation,...
Women holding the CFO role is nearing parity – reshaping finance leadership and potentially helping increase female representation across all senior roles.
We saw an increase in the percentage of senior management roles held by women, on a global level, but there are some significant regional and country variations.
Mid-market firms are scaling sustainability for growth, not just compliance. Grant Thornton’s International Business Report (IBR) 2025 report reveals how sustainability investments are driving profitability, resilience and global expansion — despite regulatory shifts and political uncertainty.
The world needs a sustainable mid-market. It’s vital to economies, societies and the
planet. Businesses, governments, and other stakeholders must work collaboratively to make
sure this vital part of the world economy succeeds.
As organisations in the private sector make commitments and plans to reach net zero, there's a growing need for stakeholders to be able to assess the credibility of their transition plans.
A shifting global trade landscape is contributing to rising uncertainty, but could it also unlock new opportunites for adaptable mid-market businesses while larger companies opt to wait and see?
Across the globe, companies’ tax affairs are facing increasing scrutiny from regulators, communities and clients. Read our latest insights ranging from BEPS to...
Growing businesses that send their greatest assets – their people – overseas to work can face certain tax burdens, our global guide highlights the common tax rates and issues.
Helping you easily find everything you need to know about the rules and regulations regarding transfer pricing and Country by Country reporting for every country you do business with.
Global transfer pricing guide
Transfer pricing - Uganda
01 Jan 20255 min read
This publication provides a high-level overview of Uganda's transfer pricing rules and outlines who to contact for expert guidance in this area.
Contents
Introduction to transfer pricing in Uganda
The legal framework for TP in Uganda is the Income Tax Act (Transfer Pricing) Regulation 2011 issued under sections 90 and 164 of the Income Tax Act. These regulations are applied in a manner consistent with:
The arm’s length principle in Article 9 of the OECD Model Tax Convention on Income and Capital; and the OECD TP Guidelines for Multi-national Enterprises and Tax Administrations approved by the Council of the OECD for publication on 13 July 1995 (C(95)126/FINAL) as supplemented and updated from time to time.
The regulations apply to Ugandan taxpayers and the responsibility is on the taxpayer to confirm its transfer prices meet the standard or to adjust its tax return accordingly. The filing of TP documentation with tax return forms to the Uganda Revenue Authority (URA) is not mandatory, but because it is the taxpayer’s responsibility, TP analysis and documentation is prepared to help protect against penalties.
TP documentation should be finalized prior to the due date of filing the income tax returns in a given financial year.
Although Uganda is not an OECD country, Uganda’s TP regulations are consistent with the OECD TP Guidelines for Multinational Enterprises and Tax Administrations. The Guidelines, updated in July 2017, are stated in the Income Tax (TP) Regulations, and are applied in the interpretation and determination of the arm’s length price.
However, where the OECD guidelines conflict with the Income Tax Act, the Income Tax Act prevails.
Acceptable TP methods include comparable uncontrolled price method, resale price method, cost plus method, transactional net margin method, transaction profit split method and any other method which the taxpayer can apply to reliably measure the arm’s length price in each associated entity transaction. An evaluation of the functions performed, assets owned, and risks undertaken by each entity involved in the inter-company transaction is undertaken to determine which of the above methods, is most applicable.
Selection of the most appropriate TP method depends on several factors such as:
the availability of complete and reliable data,
the degree of comparability between controlled and uncontrolled companies (or transactions); and
the number, magnitude, and accuracy of adjustments necessary to apply a method.
There is no set hierarchy for the TP methods as Uganda’s regulations are applied consistent with the OECD guidelines. However, the comparable uncontrolled price method is preferred when compared to other methods.
The responsibility is on the taxpayer to ensure that the TP regulations are adhered to and to confirm its transfer prices meet the standard.
Transfer pricing documentation
The TP regulation states that an entity shall record, in writing, sufficient information and analysis to verify that the controlled transactions are consistent with the arm’s length principle. The documentation should be finalised prior to the due date of filing the income tax returns in the given financial year.
The URA may, by notice, specify the items of documentation that a person is required to maintain. Any documentation should be prepared in English and be available prior to the due date of filing the income tax returns in a given financial year.
There is no legislation that requires preparation of a master file.
Although there is no requirement to the Transfer Pricing documentation, taxpayers may rely on the guidance provided within the Transfer Pricing regulations and consistent with the OECD guidelines for the preparation of their local file.
The local file must, at a minimum, include the following:
Details of inter-company transactions;
The transfer pricing methodology leveraged, and explanation for its basis of selection;
The economic realities relating to market data.
Based on the URA’s current approach, keen interest in paid to:
Significant payments to related parties in low-tax jurisdictions or tax heavens;
MNEs with consistent loses;
Material transactions - constituting a large portion of the company’s revenues or costs, depending on the nature of the transaction;
Business restructurings, or changes in benchmarking methodology model may also trigger inquiry from the authority;
Inbound management and administrative service fees/charges that do present sufficient evidence of their inbound benefit to the local subsidiary and have no supporting documentation such as formal agreements.
An entity that contravenes the TP regulation is liable on conviction to imprisonment for a term not exceeding six months or to a fine not exceeding Ushs 500,000 (25 currency points) or both.
In addition, the Tax procedures code (Section 49A) states that failure to provide requested TP documentation will result in a penalty not exceeding Ushs 50,000,000.
Economic analysis and how to demonstrate an arm’s length result
URA does not require an entity to document that a search for potential internal comparables was undertaken before defaulting to an external database search for comparables.
Local and regional comparables are preferred, whilst global comparable companies can be accepted.
URA is, however, not obliged to rely on an entity’s benchmarking studies and may conduct its own study and reach its own range of results.
Advance Pricing Agreements (APAs), dispute avoidance and resolution
APAs are written agreements between a business and URA to govern the appropriate TP method for a forward-looking period. Applications for multi-lateral APAs are allowed.
TP regulations Section 9 – Advance Pricing Agreements, states that a person may request that the Commissioner enter into an APA to establish an appropriate set of criteria for determining whether the taxpayer has complied with the arm’s length principle for certain future controlled transactions undertaken by the person over a fixed period of time.
The URA may enter an APA with the entity either alone or together with competent authorities of the country or countries of the entity’s associate or associates.
Exemptions
There are exemptions for local entities whose controlled transactions with associated entities do not exceed Ushs 500,000,000 (25,000 currency points).
Related developments
Although there have been no recent developments since the Ushs 50,000,000 penalty for not submitting information upon request was introduced in July 2017, it is worth noting that the Uganda Revenue Authority (URA) has recently increased its efforts to enforce transfer pricing regulations in Uganda focusing majorly on large multinational organizations with significant intercompany transactions.
Contact us
For further information on transfer pricing in Uganda please contact:
