The net is tightening: what URA already sees about your business

Most owners think URA finds out about a business when the business files. The reverse is closer to the truth. By the time you file, URA can often already see your sales, your bank deposits and your payroll, in other people’s records.

The rule

For tax purposes, the following shall be used as tax identification numbers— (a) a national identification number issued by the National Identification Registration Authority under the Registration of Persons Act, in the case of an individual; (b) a registration number issued by the Uganda Registration Services Bureau, in the case of a person who is a non-individual.
Tax Procedures Code Act, section 4(1), as substituted by the Tax Procedures Code (Amendment) Act 2025 (Act 11 of 2025), section 2. It comes into force on a date the Minister appoints by statutory instrument; at the time of writing we have not seen that instrument.

The mechanism

URA does not hold one big file on you. It holds many small ones from other people, and the TIN (tax identification number) is the thread that ties them together. Today a person can appear at a bank, a mobile-money provider, a licensing office and an employer under slightly different details, and the thread is loose.

Once the new section 4 is in force, the number already used at NIRA for individuals, and at URSB for companies, becomes the number used for tax. The thread tightens without URA collecting any new data. The law already lets URA ask any person for information by written notice, “whether or not liable for tax” (Tax Procedures Code Act, section 49, Revised Edition 2023). It already stops a licence or a stamp-duty registration for anyone without a TIN (section 4(9) and (10)).

The sources

Think like the person matching them: five places your business already appears.

1. EFRIS. Every e-invoice and e-receipt your business issues, and the ones your suppliers issue to you. Input VAT is claimed against what the supplier side shows. An e-invoice is necessary, not sufficient: in the rulings we have read, input credit was refused where the supplier side did not match.
2. Your returns, side by side. VAT sales next to income tax turnover, in the same system. A gap invites a question.
3. Banks and mobile money. A written notice under section 49 can go to your bank or your mobile-money provider. Deposits can then be set against the sales you declared.
4. Payroll. PAYE returns can be compared with NSSF lists and, for foreign staff, with work permits.
5. Withholding certificates. The withholding tax your customers deduct and declare can be compared with the credits you claim.

A match is a lead, not a conclusion. In the rulings we have read, third-party data started a question; it did not by itself prove a tax figure. But a business that cannot answer the question quickly, from its own records, is the one that pays.

What may be coming

The 2026 Bill proposed changes to the penal tax for failing to use an EFD (electronic fiscal device) or to issue an e-invoice or e-receipt. We will give the figure when we have read the Act as passed. Do not plan around a figure; plan around issuing every EFRIS document.

The number

No figure this week, and that is the point. The change in the law is an identifier, not a rate.

The verdict

You cannot control what URA can see. You can control whether your own records answer a question before it is asked. Every month, check four matches:

1. EFRIS to your VAT return to your ledger.
2. Bank and mobile-money credits to your sales.
3. Withholding certificates to the invoices they relate to.
4. Payroll to PAYE to NSSF.

The next move

WhatsApp us “BOOK” on +256 773 987 457 and we will book a planning consultation on your monthly reconciliation.

Related: Tax Planning & Advisory · The 15th: VAT, PAYE and WHT in one checklist · What happens when a URA letter arrives

Not sure where you stand? Let’s find out, before URA does it for you.