Section 78: Source of income Income is derived

from sources in Uganda to the extent to which it is (a) derived by a resident person in carrying on a business except to the extent that it is attributable to a business carried on by the person through a branch outside Uganda; (b) derived by a non-resident person in carrying on a business through a branch in Uganda; (c) derived by a resident person in carrying on a business as owner or charterer of a vehicle, ship or aircraft, wherever such vehicle, ship or aircraft may be operated; (d) employment income or a fee for the provision of services- (i) derived from employment or services exercised or rendered in Uganda; (ii) paid by a resident person, other than as an expenditure of a business carried on by a person outside Uganda through a branch; or (iii) paid by non-resident person as an expenditure of a business carried on by a person through a branch in Uganda; (e) derived by a resident individual from any employment exercised or services rendered as a driver of a vehicle, or an officer or member of a crew of any vehicle, ship or aircraft, wherever the vehicle, ship or aircraft may be operated; (f) derived from the rental of immovable property located in Uganda; (g) derived from the disposal of an interest in immovable property located in Uganda or from the disposal of a share in a company the property of which consists directly or indirectly principally of an interest or interests in such immovable property, where the interest or share is a business asset; (h) derived from the direct or indirect change of ownership by fifty percent or more, of a person other than an individual, a local government, a political subdivision of a local government and a listed institution located in Uganda; (i) derived from the disposal of movable property, other than goods, under an agreement made in Uganda for the sale of the property, wherever the property is to be delivered; (j) an amount- (i) included in the business income of a taxpayer under section 27(5) in respect of the disposal of a depreciable asset used in Uganda; or (ii) treated as income under section 61, where the deduction was allowed for an expenditure, loss or bad debt incurred in the production of income sourced in Uganda; (k) a royalty- (i) paid by a resident person, other than as an expenditure of a business carried on by the person outside Uganda through a branch; (ii) paid by non-resident person as an expenditure of a business carried on by the person through a branch in Uganda; or (iii) arising from the disposal of industrial or intellectual property used in Uganda; (l) interest where- (i) the debt obligation giving rise to the interest is secured by immovable property located, or movable property used, in Uganda; (ii) the payer is a resident person; or (iii) the borrowing relates to a business carried on in Uganda; (m) a dividend or director's fee paid by a resident company; (n) a pension or annuity where- (i) the pension or annuity is paid by the Government of Uganda or by a resident person; or (ii) the pension or annuity is paid in respect of an employment exercised or services rendered in Uganda; (o) a natural resource payment in respect of a natural resource taken from Uganda; (p) a foreign currency debt gain derived in relation to a business debt which has arisen in the course of carrying on a business in Uganda; (q) a contribution to a retirement fund made by a tax-exempt employer in respect of an employee whose employment is exercised in Uganda; (r) a management charge paid by a resident person; or (s) taxable in Uganda under an international agreement; or (t) attributable to any other activity which occurs in Uganda, including an activity conducted through a branch in Uganda.