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Proposed changes to the Income Tax Cap 340 and the Value Added Tax Act Cap 349

Friday, 03 April 2020
Deus Mugabe

"Tax Review "

On the 30th March 2020, the Ministry of Finance gazette the Income Tax (Amendment) Bill 2020, the Value Added (Amendment) Bill 2020, the Excise Duty (Amendment) Bill 2020 and the Stamp Duty (Amendment) Bill 2020. Below we highlight key changes that will be introduced by proposed amendments to the Income Tax Act Cap 340 and the Value Added Tax Act Cap 349.

PROPOSED AMENDMENTS TO THE INCOME TAX ACT CAP 340

Rental Income

Rental income derived by a partnership will be imposed on the individual partners.

The current regime treats expenditures and losses incurred by individuals and partnerships in deriving rental income differently from those of other tax payers (companies, trusts, retirement funds and other tax payers). Companies, trusts, retirement funds and other taxpayers, not being individuals or partnerships, have previously been allowed to deduct all expenses and losses incurred in generating rental income. Under the proposed amendment, all persons (including individuals) who have rental income will be allowed to deduct 50% of the rental income as expenditures and losses incurred in the production of such income.

Furthermore, where a person earns rental income from more than one building, the taxpayer will have to account for income and expenses and pay tax of each building separately.

Previously, the Income Tax Act provided a formula for calculation of rental income in regard to individuals and partnerships while it provided a rate of 30% for companies, trusts and retirement funds. Under the proposed amendment, the rate of tax payable on rental income will be 30% of the chargeable income for all persons (including individuals) who earn rental income.

Exemptions

The bill introduces new exemptions;

·         The income of the Deposit Protection Fund established under section 108 of the Financial Institutions Act as Amended will be exempted from income tax.

·         The Islamic Development Bank will be included in the 1st schedule to the Income Tax Act thereby exempting its income from tax in accordance to section 21 of the Income Tax Act.

·         Existing operators or any person carrying on business outside the industrial park or free zones upon making an additional investment equivalent to ten million United States Dollars in case of foreigners or one million United States Dollars in case of a citizen will qualify to enjoy tax exemptions.

Deductions for e-invoicing systems transactions

No deductions will be allowed for expenses of a person who purchases goods or services from a supplier who is designated to use the e-invoicing system unless the expenses are supported by e-invoices or e-receipts.

Withholding tax

The Bill introduces new withholding tax requirement;

·         A resident person who purchases land, other than land which is a business asset, from a resident person will be mandated to withhold tax at a rate of 0.5% of the purchase price.

·         Where an insurance service provider pays commission to an insurance agent, the insurance service provider will be mandated to withhold tax at a rate of 10% on the gross amount paid.

·         Every person who makes a payment for a commission to an advertising agent will be mandated to withhold a tax at a rate of 10% on the gross amount of the payment.

Introduction of tax clearance certificates requirement for transport service providers

Before renewal of operational licenses of a taxpayer who provides passenger transport service or a freight transport service, such a taxpayer must have a tax clearance certificate from the Commissioner General in accordance with the Tax Procedures Code Act 2014.

New tax regime for small businesses (presumptive tax)

The 2nd schedule to the Income Tax Act which provides for the tax rates paid by small businesses (businesses with a turnover of less than UGX 150, 000,000) under the presumptive tax regime will be amended to provide for different treatment for those small businesses with documents and those without documents.

Minimum Tax Rate

The new tax regime will impose a minimum tax rate of 0.5% percent of the gross turnover in the sixth year on tax payers whose declared tax liability for a consecutive period of five years of income averages less than 0.5 percent of gross income.

PROPOSED AMENDMENTS TO THE VALUE ADDED TAX ACT CAP 349

Accounting for commercial Building

Owners of more than one commercial building shall be required to account for tax for each commercial building separately.

An owner of a building shall not be allowed to claim inputs used in the construction of an incomplete building against the tax collected from a completed commercial building.

Tax credit on e-invoicing system transactions

A taxable person will only be able to claim a tax credit on expenses on purchase of goods and services from a supplier who is designated to use the e-invoicing system if those expenses are supported by e-invoices or e-receipts.

Islamic Development Bank

The Islamic Development Bank will be added in the 1st Schedule to the Value Added Tax Act as a Public International Organization which will allow it to claim for a refund of tax paid or borne by it pursuant to section 45 of the Value Added Tax Act.

Exemptions

The 2nd schedule to the Value Added Tax Act has been amended to include other supplies in the list of exempted goods and supplies.

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