Emmanuel Tumuhaise

Emmanuel is a Senior Associate at Ortus Advocates responsible for the delivery of tax and corporate advisory services to the firm’s clients. Before joining Ortus, Emmanuel worked with KPMG where he was responsible for handling and advising the firm’s clients on their legal and tax concerns.

Emmanuel is a registered Tax Agent and has provided practical advisory services to multinational and local companies on how to manage the impact of tax laws and regulations on their operations. 

Emmanuel has great relationships with the Ugandan tax authorities and has led discussions in respect of lingering tax review and investigation issues. He also facilitates tax training programs for clients and tax practitioners.

Selected Experience

• Successfully acted for former shareholders of the biggest paint company in Uganda to defend against a Capital Gains Tax dispute worth USD. 54.7 million arising out of a disposal of shares. The dispute involved several aspects of cross-border taxation and attempts for the automatic exchange of information between two states under the Multilateral Convention on Mutual Administrative Assistance in Tax Matters.  
• Advised a French multi-national telecommunication company on an entry strategy into the Ugandan market to provide internet connectivity services including negotiating with the Ministry of Finance, Planning and Urban Development, Uganda Investment Authority, and the Uganda Revenue Authority for specific tax exemptions obtaining private rulings for the entity, negotiating with Uganda Communications Commission and reviewing contractual agreements with other service providers.
• Advised on the formation of the 97 fund – a Venture Fund in Uganda. The engagement involved assisting in undertaking the legal/institutional/fiscal/tax analysis for the setup of a venture capital fund in Uganda. I also advised on the market-facing and fund-raising documents for the fund (PPM, Investor Presentation, and Investor Teaser.)
• Advised the second biggest multinational commodity trading company on the tax implications and transfer pricing model in respect of their business in Uganda’s downstream value chain. Specifically, I participated in the negotiations of an Advance Pricing Agreement (APA) with the Uganda Revenue Authority on behalf of the subsidiary in Uganda, structuring their business model from a tax perspective to minimize tax exemptions.  
• Acted as lead transaction advisor to a Consortium that was contracted by the Uganda Investment Authority as the owner’s engineer to manage the development of the Kampala Industrial and Business Park. The engagement involved undertaking a legal diagnostic study and review of the key transaction agreements for the project and advising on the structure & operationalization of the project including corporate governance, tax obligation and other statutory obligations, employment and labor relations (independent contractors and expatriate works among others)