Why the FY2026/27 plan changes your filing posture
On 7 September 2026, the Uganda Revenue Authority published its Domestic Taxes Taxpayer Compliance Risk Management Strategy and Compliance Improvement Plan for FY2026/27. The document identifies 22 specific compliance risks and marks a clear shift from asking "Did you file?" to asking "Can you prove your numbers match?" URA now cross-references ASYCUDA customs data against VAT returns, income tax sales, stock records, EFRIS receipts and Digital Tax Stamps. For a Ugandan CFO, that means the tax question is no longer only about filing on time; it is about reconciling the numbers before URA does.
The reconciliation shift in plain English
A reconciliation exercise simply means checking that the same transaction appears consistently in different records. If you sold goods worth UGX 100 million, that sale should show up in your VAT return, your income tax sales figure, your EFRIS receipts and, if exported, your ASYCUDA record. A difference is not automatically a violation. Timing differences, returned goods, cancellations, exchange-rate movements and legitimate wastage can all explain variances. What turns a variance into a tax problem is being unable to explain it.
The 22 red flags: what URA is cross-checking
The 22 risks cluster around a few themes: customs values, stock movements, production quantities, payroll and withholding, and related-party transactions. Here are the areas Ugandan businesses should reconcile first.
- ASYCUDA export values versus VAT exports and income tax sales
- VAT taxable value versus Local Excise Duty-derived excise-inclusive value
- Opening and closing stock across Local Excise Duty returns, trading accounts and balance sheets
- Manufacturer input-output ratios and Digital Tax Stamp quantities versus declared production and sales
- Cost of sales, trade payables, unclassified "Other Expenses" and expenses claimed on assets absent from the balance sheet
- PAYE registration gaps, secondary-employer under-declaration, and under-declared withholding tax on international, professional and management fees
- Mispricing of related-party goods and excessive related-party payments
- EFRIS non-issuance of receipts
The common thread: independent records must agree
Notice what these flags have in common: URA is comparing records that should agree if your internal reporting is sound. It is not asking for a perfect set of books; it is asking for a defensible trail. In practice, a Ugandan business should maintain a reconciliation file that shows how sales, VAT, income tax, inventory, payroll, customs and EFRIS data tie together, including explanations for any differences.
A pre-filing reconciliation checklist for Ugandan CFOs
Run through this before submitting returns. It is not legal advice, but it reflects the data points URA says it will now examine.
- Reconcile reported sales to VAT returns, income tax sales and EFRIS receipts; for exporters, also reconcile to ASYCUDA customs export values.
- Reconcile inventory: opening stock plus purchases and production less sales should equal closing stock across all returns and your balance sheet.
- Reconcile payroll records to PAYE registration and all employment income, including payments made by secondary employers.
- Reconcile customs import and export data to purchase and sales records.
- Reconcile production quantities to Digital Tax Stamps.
- Substantiate cost of sales, trade payables, unclassified other expenses, related-party payments and any expenses claimed on assets not on your balance sheet.
- Reconcile withholding tax on international transactions, professional and management fees.
The exact order depends on your business, but the principle is constant: reconcile before you file. If you import goods or software, remember that the customs data already held in ASYCUDA will be matched against your returns; our note on Uganda's import levy explains how the levy changes your procurement math.
What the Ericsson AB v URA ruling confirms about unexplained discrepancies
The Ericsson AB v URA decision is useful but not a get-out. The ruling confirms that a numerical variance alone is not enough for an assessment; URA must connect that variance to a taxable supply. That is a defense if you are already in a dispute. It is not a filing strategy. The practical advice is to build reconciliation files before an audit starts, not after an assessment arrives. If you procure software from a non-resident, the withholding tax question is one more item to reconcile; our article on Uganda's software withholding tax explains what it adds to your bill.
Before filing, not after
Keep a single reconciliation file that maps each return line to its source record and explains every material variance. URA's FY2026/27 strategy makes that file the difference between a routine query and a formal assessment.
A calmer way to think about this
This is manageable. The shift is not about chasing perfect data; it is about showing your work. Most discrepancies have ordinary explanations: a return, a cancelled invoice, a foreign-exchange movement, a genuine stock write-off. The businesses that struggle are not those with discrepancies, but those with no trail. Reconcile your numbers, document the reasons, and you have defensible answers before any question arrives.