Tax & incentives

Investors in Uganda can access tax incentives through the Uganda Investment Authority and the Uganda Free Zones Authority, including a 10-year income tax holiday for qualifying foreign investment.

Non-Ugandan official assessment (Tier 3 for our purposes); UIA/UFZA primary instruments not yet captured. No data-centre-specific incentive verified - any DC-specific treatment remains unverified. | r11 upgrade (editor-delegated 2026-09-23): Investment Code Act 2019 (T1, ULII) captured: s.12 sets incentive qualification (minimum capital, Schedule 2 priority areas, 80% export criterion, 60% citizen employment), s.13 provides the Authority's certificate of incentives, and the Uganda Free Zones Authority is named in s.4 definitions. Free Zones Act 2014 s.48 (T1) confirms exemptions from taxes and duties on EPZ imported inputs. However, neither captured instrument contains the 10-year income tax holiday: the Code defers to 'qualifications for incentives set out in any other law' and the captured Free Zones Act is the 2014 original. The holiday (T3: PwC tax summaries confirm availability to 80%+ exporters) lives in the Income Tax Act as amended - claim remains partially-verified pending that instrument's capture. | r12 upgrade (editor-approved conditional on verification, 2026-09-23): Income Tax Act Cap 340 s.21(1)(y) - 'the income of a person derived from the exportation of finished consumer and capital goods for a period of ten years', with the 80% export condition (para (aa)) and the prescribed-conditions/certificate regime ((ab),(ac); inserted by IT (Am) Act 2008) - captured via a Grant Thornton/ULRC-based full-text reproduction (T2); the operationalising 2009 Regulations are in the same capture; PwC current edition (T3) corroborates the ten-year/80% terms. Verified under 'two independent corroborating sources'; the official ULII consolidation remains the confirmation target (fetch-blocked 2026-09-23). The holiday is sector-agnostic statute text - any data-centre-specific treatment remains unverified.

A registered investor investing at least USD 50,000,000 (with at least 30% equity) in qualifying sectors - including Information and Communication Technology (excluding ICT retail/wholesale trade, ICT repair, and telecommunications) - is entitled to a corporate income tax holiday of up to seven years.

Verbatim captured from RDB's official One Stop Centre page. A large data-centre campus could qualify under ICT, but 'telecommunications' exclusion needs care for operator-affiliated facilities - interpretation deferred to the article layer.

An international company with its headquarters or regional office in Rwanda is entitled to a 0% preferential corporate income tax rate if it invests at least USD 10,000,000 in tangible and intangible assets and provides employment and training to Rwandans.

Verbatim captured. Regional-HQ path relevant to pan-African DC operators choosing Kigali.

TISEZA grants Certificates of Incentives and licences under Part III, Section 19(1-5) of the Investment and Special Economic Zones Act (Cap. 38); holders are entitled to the incentives stipulated in the Act.

Official TISEZA facilitation page + full statute PDF captured (two publisher expressions of the same authority).

Enterprises in special economic zones receive: exemption from customs duties, VAT and other taxes on raw materials and capital goods used in production; exemption from corporate income tax for the first ten years; exemption from withholding tax on rent, dividends and interest for the first ten years; exemption from withholding tax on interest from foreign loans; and exemption from local-government taxes, fees and charges on goods produced in SEZs for the first ten years.

Verbatim captured from the Act's incentive list (s.20 area). No Tanzania-specific data-centre tax incentive was found in any captured instrument - recorded as an explicit gap; SEZ siting is the generic path.

The Act provides a strategic investor regime (s.21): the National Investment Development Committee recommends investment incentives for strategic investors and supervises major projects with significant national impact based on size, capital, technological benefits and employment.

Verbatim captured. The path a hyperscale AI campus would negotiate; criteria map cleanly onto data-centre investment profiles (interpretation deferred to article layer).

Under the EAC Customs Union Common External Tariff (2022 version, updated June 2025), automatic data processing machines and units (HS 8471 - systems, processing units, input/output units, storage units) and electrical transformers/static converters (HS 8504) attract 0% import duty.

T1 tariff schedule captured (577pp; ICT headings extracted). EAC-WIDE anchor: applies identically to Kenya, Uganda, Rwanda - a shared input-cost baseline for the regional comparison. Server/IT hardware enters duty-free across all four countries.

Non-resident digital services: Section 90A of the Income Tax Act taxes non-residents at 3% on payments received from individuals (not conducting business) for services through a digital marketplace, with Section 116(1) extending scope to all electronic services; Section 68(5) of the VAT Act lets non-residents register for VAT without a tax representative, operationalised by the Non-resident Electronic Service Providers Regulations 2022.

T1 official TRA explainer, section-cited. Contextual for offshore-delivered cloud/colocation services vs in-country supply.

Kenya's SEZ regime is administered by the Special Economic Zones Authority (SEZA), the regulator of both public and private SEZs, which administers SEZ enterprise licences and has gazetted zones including Naivasha, with ICT Parks and Business Service Parks as designated zone types.

T1 (authority's own site). The ICT-Park designation is the directly data-centre-relevant hook: zone-type carve-outs exist for ICT infrastructure and services. Rate specifics are a separate, partially-verified claim (KE-TX-C2).

SEZ-registered enterprises in Kenya receive preferential corporate taxation (reduced CIT for an initial period) and relief on inputs, per the SEZ Act 2015 as amended.

Rate/rest-of-regime detail rests on a T3 law-firm briefing (snippet) plus the authority's regime context (T1, silent on rates). SEZ Act 2015 text (Kenya Law JS shell) uncaptured - upgrade on Act capture; amendments noted by Bowmans must be reconciled with the consolidated text. | r11 upgrade (editor-delegated 2026-09-23): SEZ Act 2015 consolidated text (T1, Kenya Law) captured: s.35(1) grants licensed SEZ enterprises/developers/operators tax incentives as specified in the respective tax laws; s.35(2) enumerates exemptions (stamp duty, county advertisement/business-service fees, specified licences); s.35(5) limits incentives and tax benefits to ten years from licence issuance. Amendment history (Acts 38/2016 s.67, 4/2023 s.101, 20/2024 s.33) is cited inline in the consolidated text, reconciling the Bowmans amendment notes. Specific CIT rate rests in the Income Tax Act (rate-level capture optional; regime claim now T1-anchored).

Kenya's EPZ regime is actively operated: EPZ commercial-enterprise licences, EPZ Business Service Permits and EPZ manufacturing licences are administered through the official KenInvest eProcedures platform, alongside investment-incentive and capital-deduction procedures.

T1 government platform capture shows the licence types and procedures in operation; PolicyVault lists the EPZ Act. Holiday/duty specifics are a separate partially-verified claim (KE-TX-C4).

EPZ enterprises in Kenya receive time-bound tax holidays and duty/VAT relief on inputs for export-oriented production under the EPZ Act (Cap 517).

Specifics (10-year holiday, subsequent rates) rest on snippet-grade sources; the official procedures platform confirms incentives exist but not their terms. Upgrade path: EPZ Act (Cap 517) text capture, then verify with section citations. | r11 upgrade (editor-delegated 2026-09-23): EPZ Act (Cap 517; No. 12 of 1990) consolidated text (T1) captured: Part VIII s.32 - exemption from income tax for the first ten years from date of first sale as an EPZ enterprise, with the rate limited to 25% for the ten years following; duty and VAT exemptions on EPZ imports (machinery, spare parts, raw materials, intermediate goods, construction materials); withholding tax exemption on non-resident payments during the holiday; licence grant conditioned on producing goods or services for export. Snippet-grade specifics (10-year holiday, duty/VAT relief) now confirmed verbatim in the statute.