Uganda

A company is resident in Uganda for a year of income if it meets one of the following criteria:

• Is incorporated or formed under the laws of Uganda.
• Has its management and control exercised in Uganda at any time during the year of income.
• Undertakes the majority of its operations in Uganda during a year of income.

Permanent establishment (PE)

Effectively 1 July 2024, the term ’permanent establishment’ (formerly called ‘a branch’) has been defined to mean a fixed place of business through which the business of the enterprise is wholly or partly carried on and includes: 

• a place of management
• a branch
• an office
• a factory
• a workshop
• a warehouse, in relation to a person providing storage facilities to others
• a mine, an oil or gas well, a quarry, or any other place of exploration for or extraction or exploitation of natural resources
• a farm, plantation, or other place where agricultural, forestry plantation, or related activities are carried on
• a sales outlet
• a building site or a construction, installation, or assembly project, or supervisory activities in connection with the site, project, or activity that lasts for at least 90 days in any 12-months period
• the furnishing of services, including consultancy services, by a person through employees or other personnel engaged by the person for such purposes, provided that such activities continue in Uganda for a period of, or periods amounting in aggregate to, 183 days or more in any 12-month period that commences or ends during the year of income, or
• substantial equipment or machinery that is operated, or is available for operation, in Uganda for a period of, or periods amounting in aggregate to, 90 days or more in any 12-month period that commences or ends during the year of income.