HMRC internal manual

Double Taxation Relief Manual

Uganda: Technical fees

Ugandan tax on technical fees which arise in Uganda to a United Kingdom-resident beneficial owner is limited to 15 per cent, except where the fees are effectively connected (see INTM153110) with a permanent establishment or fixed base which the beneficial owner has in Uganda (Articles 13(2) and (4)). The beneficial owner may nevertheless elect, for any year, to have the Ugandan tax on his technical fees arising in Uganda calculated as if he had a permanent establishment or fixed base in Uganda. If an election is made, the fees will be taxable in accordance with the Business Profits Article (Article 7) or the Independent Personal Services Article (Article 15), as appropriate. Whether the Ugandan tax is charged on the gross fees or in accordance with Articles 7 or 15, see INTM168062 for the method of calculating any tax credit relief due.