Why URA sometimes revalues your import
Customs valuation is the process URA uses to put a taxable value on goods entering Uganda. Under the East African Community Customs Management Act (EACCMA), the starting point is the transaction value, the price actually paid or payable for the goods. URA can verify that value, but verification is not a licence to replace a coherent invoice with a price from an internal database. Understanding this distinction is the foundation of any successful challenge. For a full view of the charges that flow from the customs value, see Uganda Import Landed Cost 2026: Every Charge, One Clear Total.
The legal starting point: transaction value comes first
Section 122 and the Fourth Schedule of EACCMA adopt a hierarchy that mirrors the WTO Agreement on Customs Valuation. The transaction value method is not merely one option among equals, it is the first and preferred basis. URA may only move to another method after demonstrating that the transaction value method fails. The six methods, in strict order, are:
- Method 1
- Transaction value, the price actually paid or payable for the imported goods.
- Method 2
- Transaction value of identical goods, same in all respects, from the same country.
- Method 3
- Transaction value of similar goods, closely resembling but not identical.
- Method 4
- Deductive value, working back from the resale price in Uganda.
- Method 5
- Computed value, built up from production costs.
- Method 6
- Residual/fallback method, a last resort, using previous methods flexibly with justification.
The Depo Limited v URA ruling clarifies the rules
In The Depo Limited v Uganda Revenue Authority, TAT Application No. 299 of 2024, judgment dated 13 February 2026, an importer of building materials had declared stone-coated steel roofing tiles imported from China. URA's Customs Enforcement questioned the timing of payments, some appeared made months before the invoices, and rejected the declared transaction value. URA then applied a reference price of USD 1.75 per kilogram from an internal database, producing a top-up assessment of Shs31,804,124. The Tax Appeals Tribunal nullified the assessment.
Verification is meant to test evidence, not displace a transaction value on the basis of unresolved suspicion.
Three holdings matter most. First, once an importer produces coherent documentary evidence of the price actually paid or payable, here, telegraphic transfer records and a valid supply agreement explained the advance payments, the evidential burden shifts to URA to show why that evidence does not establish transaction value. Second, database/reference prices are not recognised valuation methods under the Fourth Schedule; at most they are informational tools within a recognised method, usually fallback. Third, even under fallback, URA must make comparability adjustments for quantity, commercial level, timing, origin and condition, and must provide a clear written explanation. URA had prematurely invoked fallback without exhausting the legally mandated sequence.
The appeals path: object first, then escalate
URA's own published guidance sets out the route. An importer has the right to file an administrative and judicial appeal without penalty. You can also pay the disputed amount under protest and later seek a refund if you win. The steps are:
- Object or appeal the value to the Manager, Document Processing Centre (DPC).
- If not satisfied, appeal to the Commissioner of Customs.
- Then seek review by the Commissioner-General.
- Then go to the Tax Appeals Tribunal and, on further appeal, the High Court.
Watch the 30% deposit before the Tribunal
To proceed before the Tax Appeals Tribunal, a taxpayer must generally pay a deposit of 30% of the disputed tax. In Bullion Refinery Ltd v URA (2021), an application was dismissed for failure to pay that deposit. You can apply for an extension under section 28 of the Tax Procedure Code Act, but this is a real cash-flow consideration when deciding how far to take a dispute.
The evidence that actually wins these cases
When URA questions a declared value, the outcome usually turns on whether you can show a coherent, verifiable transaction record. Keep the following for every import:
- Commercial invoice and packing list.
- Bill of lading and shipping documents.
- Proof of payment, telegraphic transfer or SWIFT records and bank statements.
- The supply agreement or purchase order.
- Correspondence with the supplier about price, payment terms and delivery.
Advance payments are legitimate, but they must be explainable against a written supply agreement. If you receive an uplift, ask URA in writing for the basis of the uplift and the comparability adjustments they made. You do not need to prove URA wrong at the first step, you need to make them justify their departure from your transaction value. If you are still in the clearing stage, this guide helps you get the paperwork right: How to Clear a Business Import Through URA Customs in Uganda (2026).
What an unjustified uplift actually costs you
A customs revaluation is not just a duty line item. It flows into your landed cost and then into VAT, because 18% VAT is applied on top of the customs value plus duty. For capital equipment, a higher customs value also becomes a permanently higher depreciable base. A revaluation of 20–40% above invoice can wipe out the margin on an otherwise sound purchase. If Uganda's import levy applies to your shipment, the same uplift can feed into that charge as well, see Uganda's New 2.5% Import Levy: How It Changes Your Procurement Math.
18%
VAT applied on top of customs value plus duty in Uganda
Your sequence when URA raises your value
Start with the Manager, DPC and press for the written bases of the uplift. If the decision stands, escalate to the Commissioner of Customs and then the Commissioner-General. Only after exhausting administrative review should you weigh the Tribunal, remembering the 30% deposit. The February 2026 Depo ruling does not mean URA will never revalue, it means a revaluation must be built on the correct legal method, not a database price substituted for your invoice. That distinction is what gives you room to push back.