Tax appeals after ADR: which deadline counts?

A reduced assessment, followed by a late application

Sapient Feathers’ income tax assessment fell from UGX 113,229,046 to UGX 38,209,952 following alternative dispute resolution with URA. A later dispute over the amount on its ledger reached the Tax Appeals Tribunal, but the application was dismissed with costs on 5 January 2026. The threshold issue was whether the matter was properly before the Tribunal. [1]

The case carries two connected lessons. A taxpayer needs to identify the decision it is challenging and act within the applicable time limit. It must also distinguish a challenge to a tax decision from a dispute over the implementation of an ADR settlement.

The sequence of decisions mattered

The assessment concerned the year from 1 July 2019 to 30 June 2020. URA rejected the company’s objection on 15 June 2022. Sapient Feathers sought ADR on 14 December 2022, and the ADR process eventually produced the reduced figure of UGX 38,209,952 on 6 June 2024.

An amended assessment dated 2 July 2024 reflected UGX 40,869,705. The company said it discovered this amount on its ledger on 10 October 2024 and applied to the Tribunal on 16 October 2024. It argued that the later amount, and its discovery of it, supplied the basis for a timely application. [1]

The distinction between the date of a decision, the date of service and the date a ledger entry is discovered was therefore central. A later ledger entry could not simply be assumed to start a fresh appeal period.

The majority’s ruling

Siraj Ali and Christine Katwe treated the application as a late challenge to the June 2022 objection decision. They relied on section 16(1)(c) of the Tax Appeals Tribunal Act, which requires filing within 30 days after service of notice of the decision, alongside section 16(7). The application arrived more than two years after the objection decision, and no application for an extension of time had been filed.

The majority also treated the June 2024 ADR outcome as a binding settlement agreement. Although the taxpayer disputed the alleged settlement and the amount implemented, the majority found that the application amounted to an appeal against the settlement. It relied on regulation 12(2) of the Tax Procedures Code (Alternative Dispute Resolution Procedure) Regulations, 2023, which bars an objection or appeal against an assessment altered or amended under that procedure.

The majority further held that the Tribunal lacked statutory jurisdiction to hear appeals from URA’s ADR Unit. It upheld the preliminary objections and dismissed the application with costs, without deciding the remaining issue concerning the 30% payment requirement. [1]

A separate opinion reached the same result

Grace Safi agreed with dismissal but disagreed with the majority’s reasoning on jurisdiction. In her view, an ADR decision could constitute a taxation decision reviewable by the Tribunal. She also reasoned that subsidiary regulations could not override the appeal framework established by the Acts.

She nevertheless found the application late. She treated the ADR decision of 6 June 2024 as the operative decision. The amended assessment of 2 July was, in her analysis, an administrative implementation of that outcome, rather than a new decision restarting the time limit. Any difference between the ADR figure and the ledger entry should have been addressed through reconciliation or objection.

No application for an extension of time had been made. On that basis, she too would dismiss the application with costs. [1] The outcome was shared; the proposition that ADR decisions are never reviewable was not a unanimous position.

Identify the decision, record when it was served, and protect the deadline while resolving the figures.

Three checks for a tax dispute file

• Track each decision and its service date. Keep the original assessment, objection decision, ADR correspondence and amended assessments together. Obtain advice promptly on which decision is open to challenge and when the filing period begins. Do not assume ongoing discussions or a ledger adjustment preserve appeal rights.
• Keep the signed settlement and reconcile its implementation. Compare the agreed tax, interest, payments and credits with the ledger. Record any difference and raise it through the appropriate procedure. A dispute about implementation needs to be distinguished from reopening the agreed settlement.
• Address delay explicitly. If the filing period may have expired, seek advice immediately on whether an extension is available and what evidence supports it. An extension requires a proper application and justification; it cannot be assumed.

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Source and case details

1. Tax Appeals Tribunal: Sapient Feathers (U) Limited v Uganda Revenue Authority, Application No. 293 of 2024, ruling dated 5 January 2026. The published document includes the majority ruling, pages 1–10, followed by Grace Safi’s separately numbered opinion, pages 1–6 (PDF pages 11–16).

Adapted from Kisaka & Company’s LinkedIn update of 19 January 2026, with the majority and separate opinion distinguished against the published ruling. Statutory references follow the decision. The appropriate procedure in a particular dispute depends on its facts, service history and applicable law.