Celtel Uganda Limited v Uganda Revenue Authority (Civil Appeal No. 22 of 2006)
Observed later treatment
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Holding
The Court of Appeal held that airtime is a service, not a good, because it is intangible and the customer never takes possession of it; possession being the feature distinguishing goods from services under the VAT Act. Employees who provide airtime services in accordance with their employer's directions are associates under section 3(1). Section 18(7), being couched in general terms, applies to supplies of both goods and services. The supply of airtime by the appellant to its staff for official use was therefore a taxable supply made between associates at reduced consideration. The VAT assessment of UGX 358,652,458 and the penalty of UGX 253,161,660 were upheld and the appeal dismissed with costs.
Outcome
Appeal dismissed; High Court decision upholding the VAT assessment and penalty affirmed
Facts
Uganda Revenue Authority carried out a VAT and excise audit on Celtel Uganda Limited, a telecommunications provider, for the period April 2000 to July 2003. As a result, URA assessed VAT of UGX 358,652,458 on airtime issued by Celtel to its staff for use in their official duties, together with a penalty of UGX 253,161,660. Celtel objected and appealed to the Tax Appeal Tribunal, which ruled that airtime is a consumable product akin to gas or air conditioning and thus a good, making the airtime supplied to employees a taxable supply. Celtel then appealed to the High Court Commercial Division, which upheld the Tribunal's decision that the supply was made between associates for no consideration under sections 3 and 18(7) of the VAT Act, dismissing the appeal with costs. Celtel appealed further to the Court of Appeal, challenging the characterisation of airtime and the finding that its employees were its associates.
Issues
- Whether the supply of airtime provided by mobile cellular phone companies is a supply of goods or a supply of services.
- Whether the supply of airtime by the appellant to its staff for official use was a taxable supply under the VAT Act.
- Whether employees are associates of their employer within the meaning of section 3 of the VAT Act.
- Whether section 18(7) of the VAT Act applies to supplies of services as well as goods.
Orders
- Appeal dismissed with costs.
- Decision of the High Court upheld.
Rules and key headnotes
Legislation cited (15)
- Value Added Tax Act s.1(h)
- Value Added Tax Act s.1(1)
- Value Added Tax Act s.3(1)
- Value Added Tax Act s.3(2)
- Value Added Tax Act s.10
- Value Added Tax Act s.10(1)
- Value Added Tax Act s.11
- Value Added Tax Act s.11(2)
- Value Added Tax Act s.18(1)
- Value Added Tax Act s.18(2)
- Value Added Tax Act s.18(4)
- Value Added Tax Act s.18(5)
- Value Added Tax Act s.18(6)
- Value Added Tax Act s.18(7)
- Value Added Tax Act s.21(2)(b)
Cases cited (6)
- Mpungu & Sons Transporters Limited v Attorney General (Civil Appeal No. 17 of 2001)
- Ormond Investment Company Limited v Betts [1928] AC 143
- Dilworth v Commissioner of Stamps [1899] AC 99
- Dwyer v Hunter [1951] NZLR 177
- Faagorg - Gelting Linien Vs A/S Finanzamt Flensburg (1996) ALL ER 656
- Customs and Excise Commissioners v Oliver [1980] 1 All ER 1353
Cases citing this judgment (2)
How later Ugandan judgments in the Wakilii corpus have cited this case. Treatment labels come from Sequitur — Uganda’s citator — each backed by a verbatim span from the citing judgment, and are not an assertion that this case is, or is not, good law.
Full judgment
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