What I have done
Redmond Tax - Head Redmond Tax Practice
In affiliation with REDMOND ASSOCIATED ADVOCATES
- Providing tax advisory, tax compliance and tax reporting services to a range of clients
Uganda Revenue Authority (URA) - Supervisor Oil and Gas Taxation
- Drawing on my specialized expertise in Uganda tax objections management and complex tax dispute resolution, I led a critical project for the Uganda Revenue Authority (URA), strategically tackling a significant backlog of slightly over 300 lapsed tax assessment objection cases in the Eastern Region, which was actively increasing taxpayer mistrust and severely holding up tax revenue mobilisation.
- To resolve this operational crisis, I implemented a multi-faceted and rigorous strategic approach and team, providing crucial technical guidance on Uganda tax laws and meticulous tax reviews to guarantee that every resolution was both legally sound and administratively fair.
- This decisive intervention resulted in the successful closure of all backlog cases by January 2020, delivering a profound and positive impact by achieving one of the URA's previously elusive Key Performance Indicators (KPIs) and establishing a more efficient objection resolution system that directly supports the overall objective of driving up tax compliance in Uganda.
- Leveraging deep expertise in international taxation and Uganda’s transfer pricing laws, I successfully led high stakes transfer pricing audits for three major International Oil Companies (IOCs) and over seven key contractors, ensuring the Uganda Revenue Authority (URA) secured its legitimate tax base in the complex Oil and Gas sector.
- My leadership involved supervising two specialized transfer pricing audit teams, ensuring all international tax and transfer pricing reviews were executed meticulously and within strict timelines.
- Key to the project's success was conducting detailed functional interviews with international service/goods recipients in Uganda and providers across other jurisdictions including UK, France, USA, and China coupled with independent benchmarking analyses on crucial intercompany transactions like royalties, interest, margins, and markups, utilizing advanced tools like RoyaltyStat and Orbis.
- This strategic technical approach resulted in strong audit adjustments that were often accepted or amicably resolved, significantly protecting and mobilizing Uganda tax revenue against potential profit shifting and ensuring adherence to the arm's length principle and adding on the growth of transfer pricing in Uganda.
- Leveraging deep expertise in Uganda Income Tax legislation and complex Withholding Tax (WHT) audits, I was instrumental in plugging significant tax revenue leakages and strengthening the integrity of the Uganda tax system in areas prone to abuse, notably among multinational entities with respect to sourcing rules. My technical acumen led to the issuance of ground-breaking tax assessments that successfully challenged the URA’s historical misapplication of the WHT excepting section concerning cross-border transporters.
- These novel interpretations were rigorously tested and upheld in court, setting crucial judicial precedents: specifically, the Tax Appeals Tribunal (TAT) validated my assessments against Multinational transport contractors in cases like Roche Transport and Logistics Vs URA (Application No. 94 of 2020) and under similar circumstances in Roraima Uganda Limited Vs Uganda Revenue Authority (TAT 68 of 2021), effectively securing the contested WHT revenue and establishing a new standard for compliance in international transportation taxation within Uganda.
- Following the matter Roche Transport and Logistics Vs URA, an appeal by transporters to parliament led to the amendment of the Income Tax Act to include section 84(5), i.e. “For avoidance of doubt income derived from the carriage of passengers who do not embark or cargo or mail which is not embarked in Uganda is not income derived from a Ugandan-source service contract”.
- Capitalizing on my oil and gas taxation and Uganda tax system design expertise, I conducted an intensive, comparative study of the Income Tax and VAT systems and tax policies governing the petroleum and mining sectors in key resource-rich jurisdictions, including Angola, Malaysia, Ghana, Kenya, and Nigeria.
- This comprehensive international tax review involved spending considerable time in both Indonesia and Angola to gain a critical, in-depth understanding of their practical tax administrations.
- The strategic output of this research was the development of detailed reports used to guide software systems personnel in designing a bespoke Petroleum and Mining Revenue Management System and sector-specific Income Tax Returns, a major digital transformation initiative scheduled for deployment in the early 2025/2026 financial period to enhance compliance, streamline administration, and secure tax revenue mobilisation from Uganda's strategic extractive industries.
- Drawing on specialized expertise in Uganda tax system design and oil and gas taxation, I collaborated with IT specialists to draft the comprehensive Terms of Reference (TOR’s) for a pioneering one-stop fiscal management system dedicated to the extractive sector. These TOR’s detail the entire digital compliance cycle, covering extractives taxpayer registration in Uganda, extractives taxpayer return declaration in Uganda, extractives taxpayer tax payment management in Uganda, extractives taxpayer objection management in Uganda, extractives taxpayer refund management in Uganda, and extractives taxpayer audit functionalities in Uganda, and involved prototyping declaration forms tailored to the oil and gas and mining special fiscal regime.
- Furthermore, I spearheaded tax compliance efforts for the newly introduced Digital Tax Stamps (DTS), a key Uganda tax digital tool aimed at improving the administration of Excise Duty taxes, which critically included extensive educational programs to onboard and ensure compliance among small and medium beverage manufacturers.
- Leveraging expertise in international taxation in Uganda and tax system design, I collaborated with a technical team in 2022 to lead the design of a foundational Income Tax sector risk matrix specifically tailored for mining and petroleum companies within the extractive sector taxation regime.
- Building on this strategic initiative, I subsequently guided a 2023/24 project to develop a powerful, proprietary Microsoft Excel-based risk assessment tool engineered to efficiently assess and identify high-risk multinational taxpayers for targeted Transfer Pricing and complex international tax audits.
- This proprietary tax risk tool has been successfully deployed, informing the selection of the scheduled audits in the extractive sector based on its data-driven risk rank results, and has been considered for scalable application as a key Uganda tax digital tool across other compliance sectors, underscoring my capacity for developing and implementing sophisticated, high-impact tax system design solutions.
- I was directly engaged in the formulation of strategic proposals within the Uganda Revenue Authority (URA) and advancing them through the Ministry of Finance for eventual enactment into tax bills.
- A key success in extractive sector taxation was the 2022/23 legislative change ensuring provisions specific to extractive taxpayers take precedence over general taxes provisions, a critical amendment for effective revenue protection.
- My proficiency extends to the practical implementation of customs administration and tax incentives, notably coordinating the operational rollout of the East African Community Customs Management Act (EACCMA) Fifth Schedule exemption extension, which involved developing a detailed customs implementation mechanism and training staff on machinery and inputs for direct and exclusive use in extractives.
- Furthermore, I ensured regulatory clarity and consistency by leading the preparation and publication (gazetting) of URA tax practice notes, most recently steering the note on interpreting ‘sole and exclusive’ use for the deemed paid VAT provision in petroleum operations.
- I coordinated a major, multi-dimensional project for the comprehensive review and re-design of the existing legal and tax administration framework of the entire extractive sector, a crucial undertaking that involves gathering policy input from all key stakeholders—Extractive taxpayers, government bodies, and development partners—to inform a foundational policy note to the government on a Uganda tax policy reform in the extractive sector planned for 2026/2027.
- Demonstrating profound expertise in tax training and capacity building, I was a key resource person for the Uganda Revenue Authority's (URA) internal Integrated Tax and Revenue Administration Training (ITRAT) program, where I was entrusted with developing technical materials, delivering essential lectures, and conducting rigorous examination setting and marking to professionalize and enhance the technical competences of URA staff in key areas of Uganda tax administration.
- Further solidifying my standing as a leading international tax trainer, I have developed extensive experience in designing and delivering tutorial support for globally recognized qualifications, including the prestigious CIOT Advanced Diploma in International Taxation (ADIT), specifically specializing in the core Principles in International Taxation (PIT) module, as well as the Certified Tax Advisor (CTA) program.
- This advanced-level tutorship has successfully drawn a wide base of tax professionals and practitioners from across the African continent, significantly contributing to regional tax capacity building for tax authorities and private practice firms in nations such as Kenya, Zimbabwe, Tanzania, Zambia, and the Central African Republic (CAR), thereby emphasizing my skill in cultivating advanced tax policy and international taxation knowledge transfer across Africa.
Ernst & Young (EY) Uganda - Senior Tax Advisor
My tenure with Ernst & Young (EY), a globally recognized Big Four firm, equipped me with highly technical expertise in all four core areas of Uganda Tax Consultancy. I provided comprehensive, end-to-end tax advisory and compliance services, which is critical for navigating the complexity of the Ugandan fiscal environment and minimizing exposure to the Uganda Revenue Authority (URA).
Specifically, my experience spans strategic planning and compliance for Uganda Income Tax (IT), ensuring optimal corporate tax positioning and correct management of Uganda Withholding Tax (WHT) obligations. I am also proficient in managing the intricacies of Uganda Value Added Tax (VAT), especially concerning cross-border transactions and securing timely refunds. Furthermore, I successfully handled advisory on Uganda Excise Duty and Customs/Global Trade matters, ensuring compliance with tariff classifications and mitigating risks related to import and export duties. This integrated, Big Four-trained approach ensures your business receives a global standard of tax optimization and local regulatory adherence.
My specialized experience involved leading the technical adaptation of complex banking and telecom operating systems to achieve seamless Uganda Excise Duty Compliance following new legislation. Working directly with IT experts, I architected the necessary system changes to ensure accurate calculation, collection, and remittance of various excise duties (such as those on airtime, data, and financial transactions) at the point of sale, a challenging mandate from the Uganda Revenue Authority (URA).
This process went beyond mere legal interpretation; it was a deep dive into tax digital transformation. I managed the full lifecycle, from gap analysis, guiding system re-configuration needs to rigorous post-implementation tax reviews and testing. This ensured the stability, accuracy, and audit-readiness of high-volume transaction environments, successfully mitigating significant tax compliance risk and positioning telecom and banking businesses for sustained regulatory adherence in a rapidly changing tax landscape and determining an accurate Local Excise Duty Liability.
I specialized in constructing robust, arm’s length transfer pricing documentation that ensured full compliance with the Uganda Revenue Authority (URA) regulations, including the detailed requirements of the Income Tax (Transfer Pricing) Regulations 2011.
I acquired specialized experience providing Uganda Transfer Pricing (TP) documentation and URA tax controversy support across critical sectors, including real estate, telecom, finance, and insurance.
This proficiency involved preparing highly rigorous TP local files, which necessitated deep dive into functional analysis, economic circumstances and contractual terms analysis.
Crucially, I coordinated and executed complex comparability analyses using advanced databases like Amadeus, applying necessary adjustments to ensure absolute compliance with OECD Transfer Pricing guidelines and local Ugandan TP regulations.
Furthermore, I gained hands-on expertise in transfer pricing audit and controversy support, successfully guiding 3 major clients (in banking, insurance, and telecom) through complex URA audits, resulting in favourable outcomes and significant reductions in adjustment requests.
This experience was also utilized to develop and deliver specialized transfer pricing training products, enhancing both client and in-firm compliance capabilities.
Beyond corporate tax strategy, I developed specialized experience in supporting High Net Worth Individuals (HNWIs) in Uganda with their complex personal tax compliance obligations, covering income tax, rental income, and addressing the URA's enhanced scrutiny on wealth-related tax matters to mitigate risk and optimize personal financial reporting.
I acquired substantial experience in Mergers and Acquisitions (M&A) and corporate restructuring, specifically focusing on navigating complex Uganda Tax legislation for high-value transactions and applying provisions on Uganda tax free reorganisations and restructuring.
I executed comprehensive Tax Due Diligence and provided bespoke tax advisory services on intricate cross-border intercompany transactions, acquisitions, and internal restructuring for over 10 multinational clients.
I strategically guided a multinational telecom entity to realize a significant USD 160 million saving in potential Capital Gains Tax liability on a proposed restructuring arrangement in 2019, demonstrating high-level proficiency in complex tax planning.
Additionally, I successfully secured and managed the critical process of Obtaining Complex Advance Tax Rulings from the Uganda Revenue Authority (URA) and private rulings.
These positive URA rulings were essential for attaining statutory certainty in ambiguous areas of the tax law, effectively de-risking major corporate structuring advice and ensuring full compliance and predictability for clients undertaking substantial investments and corporate reorganization in Uganda.
I developed specialized, high-impact expertise in corporate and international taxation, successfully guiding over 10 Multinational Enterprises (MNEs) on optimizing their operational footprint and achieving significant Uganda Tax cost reductions.
My core function involved executing complex Permanent Establishment (PE) assessments and advising on optimal market entry and exit strategies in Uganda.
This work focused on designing sophisticated, tax-efficient operational structures to mitigate risks related to unwarranted PE creation, thereby preventing the 30% Corporate Income Tax exposure on non-resident entities.
Furthermore, I managed and optimized cross-border transaction flows to minimize Withholding Tax (WHT) leakage on dividends, royalties, and interest, ensuring full compliance with the Uganda Income Tax Act (ITA) and leveraging Double Tax Agreements (DTAs) to secure treaty benefits for clients operating across the East African region.
I cultivated specialized expertise in high-stakes URA Tax Audit Defense and Dispute Resolution, successfully navigating the complexities of Uganda’s tax laws. I personally concluded tax audits and disputes for over 10 annual clients, primarily large corporate entities and Multi-National Entities (MNEs). This extensive experience established my core commitment to shielding financial interests and ensuring robust tax compliance in Uganda against aggressive tax assessments.
Through extensive practice at EY Uganda, my technical defense knowledge came to span the full spectrum of Uganda Revenue Authority (URA) investigations. This included rigorously defending clients during targeted Issue Audits across Withholding Tax (WHT), Value Added Tax (VAT), Income Tax, and Corporate Tax, as well as managing complex Comprehensive Audits. A critical part of my acquired skill set is providing robust documentation and interpretation in highly technical areas, particularly ensuring strict compliance with Transfer Pricing regulations and the correct application of Double Taxation Agreements (DTAs) to safeguard clients' international tax positions.
The strategic approach I developed over years during my time EY built on achieving swift and definitive results at the administrative stage, minimizing the time and cost burden on businesses. I gained proficiency in skilfully leveraging the URA's formal Objection process and utilizing the effective Alternative Dispute Resolution (ADR) mechanisms. This proactive engagement strategy was consistently a foundation for powerful outcomes, securing substantial reductions in assessed tax liabilities and, in several key, high-value cases, achieving definitive clearance and zero tax obligations for my clients.
Ultimately, the experience I acquired has equipped me with the decisive capability to protect Ugandan businesses from protracted legal battles and maximize their tax efficiency. By consistently securing favorable outcomes through negotiation and deep technical defense, I learned to help businesses avoid the expense, time, and potential public exposure associated with appealing contentious matters before the Tax Appeals Tribunal (TAT), demonstrating a proven track record of decisive financial risk mitigation gained over years of practice.
My technical defense expertise spans the full spectrum of Uganda Revenue Authority (URA) investigations. This includes defense against targeted Issue Audits across Withholding Tax (WHT), Value Added Tax (VAT), Income Tax, and Corporate Tax, as well as managing extensive Comprehensive Audits. A critical component of my work involves providing robust documentation and interpretation in highly technical areas, particularly ensuring compliance with Transfer Pricing regulations and the correct application of Double Taxation Agreements (DTAs) to safeguard clients' international tax positions.
White Kight Partners - Audit Associate
As an Audit Assistant at White Knight Partners Certified Public Accountants, I cultivated my foundational expertise by conducting rigorous financial and operational audits across two critical East African markets: Uganda and Rwanda. This role provided unparalleled exposure to diverse commercial operations, from large-scale regional manufacturing to complex logistics. This intensive engagement with client financial statements, including major firms like Sadolin and Diamond Logistics, provided the essential groundwork for mastering proactive Ugandan tax compliance and internal risk identification—a skill set directly relevant to pre-empting Uganda Revenue Authority (URA) scrutiny.
My core responsibilities centered on meticulously examining books of account and internal controls.
This required a deep technical dive into the accuracy of financial records used for statutory filings. This hands-on experience was critical for identifying and mitigating potential tax exposures across all major tax heads, specifically focusing on the complex verification of Corporate Tax calculations, ensuring proper accounting for VAT (Value Added Tax), and confirming accurate Withholding Tax (WHT) remittances. Essentially, this function served as my initial, comprehensive training in conducting detailed Tax Health Checks.
The rigorous demands of auditing multinational operations in regulated sectors like manufacturing and logistics solidified my understanding of stringent regulatory adherence. This foundational experience is invaluable today: it equipped me with an intimate, inside-out knowledge of what constitutes an "audit-ready" client file and where compliance risks typically reside within the Ugandan tax landscape. This perspective ensures that every tax audit defense strategy I deploy is built upon a flawlessly vetted, technically sound financial foundation.
International Tax Training
[International Tax Training]
My deep specialization in International Taxation is firmed up with my training work in the Advanced Diploma in International Taxation (ADIT), a globally recognized benchmark for international tax training. I have trained tax professionals from across the globe in international tax and my commitment to technical excellence in international tax is underpinned by four years (2021–present) spent actively delivering virtual tutoring sessions including students from Kenya, Zimbabwe, UK, Switzerland, Namibia, Tanzania, Zambia, and the Central African Republic and Nigeria. My core instruction covers the highly technical fields of Principles of International Taxation, advanced Transfer Pricing, and specialized Energy Resources Taxation, demonstrating expertise in the most complex aspects of cross-border tax law.
This continuous engagement as a tutor reinforces my practical capabilities, ensuring I remain at the forefront of global tax developments, particularly those related to OECD and BEPS initiatives which heavily influence Uganda's tax landscape for multinational entities. I translate this advanced theoretical knowledge directly into strategic value for clients, particularly those with significant cross-border transactions and Double Taxation Agreement (DTA) concerns. My teaching role has not been only for instruction but a mechanism for maintaining a sharp, sophisticated understanding of international tax planning and proactively mitigating risks associated with global tax compliance for large-scale operations.