Corporate - Corporate residence

Last reviewed - 25 March 2024

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)

A PE (branch) means a place where a person carries on business, and includes:

  • A place where a person is carrying on business through an agent, other than a general agent of independent status acting in the ordinary course of business as such.
  • A place where a person has, is using, or is installing substantial equipment or substantial machinery for 90 days or more.
  • A place where a person is engaged in a construction, assembly, or installation project for 90 days or more, including a place where a person is conducting supervisory activities in relation to such a project.
  • The furnishing of services, including consultancy services, by an enterprise of a contracting state through employees or other personnel engaged in the other contracting state, provided that such activities continue for the same or a connected project for a period or periods aggregating more than 90 days within any 12-month period.