Uganda Revenue Authority – Automatic Exchange of Information

Introduction

The Uganda Revenue Authority (URA) continues to face growing pressure on its fiscal sovereignty and revenue mobilization efforts, largely due to the complexity of tracking offshore income and assets. This challenge triggered the need for a multilateral, structured and globally recognized solution, leading to Uganda’s adoption and domestication of the Convention on Mutual The Administrative Assistance in Tax Matters (MAAC) Implementation Act 2023.

This global framework fundamentally narrows the long-standing information gap that enabled cross-border tax evasion. It imposes a clear duty on all Ugandan tax residents to fully disclose their worldwide income. Through the Convention and its alignment with the Common Reporting Standard (CRS) under the Automatic Exchange of Information (AEOI) regime, Uganda reinforces its commitment to international tax transparency, strengthens domestic revenue mobilization and enhances collaboration with foreign tax authorities.

Background

Uganda operationalized its obligations under the Organization for Economic Cooperation & Development (OECD) framework through the Convention on Mutual Administrative Assistance in Tax Matters (MAAC) Implementation Act 2023. Although the Convention was originally established in 1988 and significantly expanded in 2010 to accommodate non-OECD and non-G20 jurisdictions, it became effective in Uganda on 1^st July 2023.

The Convention empowers URA to obtain and exchange tax-relevant information with other jurisdictions and affects a wide range of taxpayers, including:

• A resident individual with foreign assets or offshore financial accounts;
• Non-resident persons holding accounts or earning income in Uganda;
• Financial institutions required to report under the CRS framework.

Administration of the Convention is undertaken by URA’s Exchange of Information Unit, integrating Uganda into the global tax cooperation and information exchange.

Is it all automatic?

There is a common misconception that all information is exchanged automatically. The Convention provides several independent mechanisms through which Uganda may exchange information; these include:

1. Automatic Exchange of Information (AEOI): Regular transmission of standardized financial account information, including account balances, dividends, interest, policy values and other passive income categories under the CRS.

2. Exchange of Information on Request (EOIR): URA may request specific information related to a taxpayer under investigation, supported by 48 & 49 of the Tax Procedure Code Act (TPCA).

3. Spontaneous Exchange: A jurisdiction may share information with Uganda without being requested, where such information might be relevant to Uganda’s tax administration.

4. Simultaneous Tax Examinations: URA may participate in coordinated cross-border audits, particularly useful in examining related party transactions.

5. Assistance in Tax Collection: Partner jurisdictions may assist URA in recovering tax debts owed by persons or entities with assets abroad in line with 88 of the Income Tax Act.

Who must comply?

Under S.9 of the Income Tax Act Cap 338, a resident person includes any individual, company, trust or partnership that meets residency criteria for a given year. Further still, S.17 provides that the gross income of a resident person includes income derived from all geographical sources.

Consequently, the Convention compliance obligation extends to:

1. Individuals with foreign income, offshore accounts or ownership in foreign entities.

2. Companies and multinational groups involved in cross-border transactions.

3. Trusts, foundations, partnerships and similar arrangements with foreign elements.

4. Financial institutions required to report under CRS.

5. Non-residents with financial accounts or economic activities in Uganda.

In essence, any taxpayer whose affairs extend beyond Uganda’s borders may fall in the Convention’s framework.

Consequences of non-compliance

Tax payers who fail to comply with the Convention’s framework in Uganda face severe domestic and international consequences, such as:

1. Administrative penalties and criminal sanctions under S.79 of the TPCA.

2. Additional tax assessments, interest and penalties.

3. Transfer pricing adjustments and penalties.

4. Cross-border audits and investigations.

5. International recovery of tax debts under the Convention.

6. Reputational and commercial risk, especially for multinational groups and financial institutions.

How taxpayers should prepare to comply

To minimize exposure under the AEOI and the Convention, taxpayers should:

1. Strengthen internal tax governance structures, ensuring transparency and timely reporting.

2. Maintain robust documentation and record-keeping systems.

3. Conduct internal tax health checks to identify exposures related to foreign income, CRS reporting or transfer pricing.

4. Review cross-border structures for alignment with economic substance expectations.

5. Ensure readiness to respond to URA information requests and coordinated international audits.

6. Engage qualified tax advisers to support compliance under both domestic and international tax obligations.

The URA AEOI portal

To facilitate compliance under AEOI, URA has established an online platform accessible via https://aeoi.go.ug/, where financial account data – such as account balances, interest, dividends and other reportable income for non-resident and resident account holders – is uploaded.

URA further launched a voluntary disclosure window called the Foreign Asset Voluntary Disclosure (FAD) programme to enable resident taxpayers to regularize undeclared foreign assets of income before those assets become visible under the AEOI regime. This can also be accessed on the URA web portal.