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THE REPUBLIC OF UGANDA IN THE TAX APPEALS TRIBUNAL AT KAMPALA APPLICATION NO. 68 OF 2018 APOLLO HOTEL CORPORATION LIMITED =========: VERSUS UGANDA REVENUE AUTHORITY RULING * This ruling is in respect whether the rare the is centralized reservation system by of the VAT Act. [the ‘Sheraton’ service for the purposes industry. In January 20 Sheraton Interpgtional inc. ‘Sheraton’ bran assessments off he int for 2010 to 2012. The applicants objected to the assessments which Was disallowed. The applicant entered a partial consent and the issue of Value Added Tax VAT) of Shs. 398,418,285 on franchisee fees was left for determination before the tribunal. ‘The applicant was represented by Mr. Andrew Kibaya and Mr. Deus Mugabe while the respondent by Mr. Alex Ssali Alideki and Mr. Ronald Baluku. ‘The following issues were set down for determination. 1. Whether there was an imported service to attract VAT? 2. What remedies are available to the parties? No evidence was led by either of the patties, as there was agreement that the dispute related to a question of law. fation system of the franchisor server inthe United States of fi The applicant submitted that its use of the centralized did not amount to an imported service, The system ha: ‘America which are accessed by the franchisorgcusto applicant benefits from business accrued rom ings made through thé:system. The franchisor kept no staff in Uganda. TI icant c nae was brought or caused enn ¢n:

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