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: