UGANDA, Kampala | Real Muloodi News | The Tax Appeals Tribunal has annulled a UGX 1.8 billion tax assessment levied by the Uganda Revenue Authority (URA) against Ugandan businessman Amos Nzeyi.
In a decision delivered on July 14, 2025, the Tribunal ruled that the proceeds from Nzeyi’s 2019 sale of 42 acres of land in Kitende to Crown Beverages Ltd. were not taxable as business income.
URA had alleged that the land transaction constituted a business activity and therefore fell under the income tax bracket. The authority initially assessed a UGX 2.18 billion tax obligation in 2022, later revising it to UGX 1.82 billion.
However, the Tribunal determined that the land in question had been held by Amos Nzeyi for nearly a decade without any development or commercial use, classifying it as a private investment.
According to the Tribunal’s findings, Nzeyi did not engage in repeated land transactions, nor did he make any improvements to the Kitende property to enhance its value for resale. These observations led the Tribunal to conclude that the transaction lacked the key characteristics of a trade or business undertaking.
The panel referenced legal precedents, including Pickford v. Quirke (1927) and Wisdom v. Chamberlain (1968), to support its decision that not all asset disposals constitute business income. Under Section 21(j) of Uganda’s Income Tax Act, capital gains that are not related to business activities are exempt from taxation.
A member of the Tribunal stated, “The sale of private land by an individual, without evidence of trade or business intent, does not automatically amount to business income.”
Amos Nzeyi had explained to the Tribunal that his income is primarily derived from dividends earned through his shareholdings in companies such as Crown Beverages Ltd., Hot Loaf Bakery, and Monarch Capital, as well as rental income from residential properties located in Kololo.
He also clarified that while his tax registration form includes real estate, it does not confirm commercial trading in property.
The ruling not only nullified the UGX 1.8 billion assessment but also awarded costs in favour of Amos Nzeyi.
Background on Amos Nzeyi
Born in 1947 in Kabale District, Amos Nzeyi is a prominent Ugandan industrialist and entrepreneur. He is the chairman and majority shareholder of Crown Beverages Ltd., the sole bottler of Pepsi-branded drinks in Uganda. He also owns Hot Loaf Bakery and several hospitality properties, including White Horse Inn in Kabale and Palm Valley Golf & Country Club near Entebbe.
Nzeyi’s business interests extend to real estate and luxury tourism, with ownership of Pineapple Bay Resort on Bulago Island and a private yacht. He has previously served as chairman of the Uganda Manufacturers’ Association and sat on the board of Uganda Development Bank (UDB).
He began his business career in childhood by selling eggs to fund his education. Over the years, he diversified into transport, construction, and food production, eventually establishing a presence in the beverage sector. By 2020, Crown Beverages reported an annual turnover of approximately US$115 million.
With a reported net worth of about US$57 million, Amos Nzeyi remains a key figure in Uganda’s private sector economy.
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