Uganda’s decision to erase Shs4.21 billion in corporate income tax arrears owed by Brookside Limited has reopened questions about how the country manages tax enforcement, corporate privileges and the legacy of privatised state assets.
The write-off, quietly published through a Uganda Gazette notice, places one of East Africa’s most politically connected dairy companies at the centre of a debate over transparency in tax administration.
Brookside Limited, the Kenyan-controlled dairy processor associated with the family of former Kenyan President Uhuru Kenyatta, was granted relief from accumulated corporate income tax arrears through a notice issued under Uganda’s Tax Procedures Code Act.
The document, signed on July 10 by former Finance Minister Matia Kasaija, states that Brookside, previously known as Sameer Agriculture and Livestock Limited, had outstanding tax arrears amounting to Shs4.21 billion.
“Notice is hereby given to the general public by the Minister of Finance, Planning and Economic Development pursuant to the Tax Procedures Code Act, Cap. 343 that the amount of tax arrears specified in column 3 in respect of the corresponding taxpayer in column 1 and the nature of tax in column 2 are written off,” the notice, a copy of which The Pearl Times has seen, reads in part.
To be exact, the figure is Shs 4,214,948,094
Yet the official announcement offers little insight into the circumstances behind the decision. It does not reveal the period during which the tax debt accumulated, the reasons for the waiver, or whether the company had previously attempted to settle the liability.
The silence surrounding the decision has created a wider debate about the balance between encouraging investment and ensuring that large corporations meet their obligations to the state.
Brookside’s Ugandan story is closely linked to one of the country’s largest economic transformations: the privatisation of state-owned enterprises.
For decades, Uganda’s dairy sector was dominated by the government-run Dairy Corporation, established in 1967 as the backbone of formal milk processing in the country.
That model began changing in the 1990s as Uganda embraced economic liberalisation. The Dairy Industry Act of 1998 established the Dairy Development Authority and laid the groundwork for restructuring the sector.
The final chapter of Dairy Corporation’s public ownership came in 2006, when Sameer Agriculture and Livestock Limited took control of the former state dairy assets.
Sameer, a joint venture involving Kenya’s Sameer Group and India’s RJ Corp, promised new investment, expanded processing capacity and modernisation of Uganda’s dairy industry.
The company became closely associated with the Fresh Dairy brand, transforming infrastructure that had once belonged to the state into a privately managed commercial enterprise.
Nearly a decade later, the ownership structure changed again.
In 2015, Brookside Dairy acquired Sameer Agriculture and Livestock, taking over its factories, farmer networks and production operations in Uganda.
The acquisition gave Brookside a major foothold in Uganda’s dairy market and effectively transferred control of assets that traced their origins to the former state-owned Dairy Corporation.
Today, Brookside manufactures Fresh Dairy and Brookside products for the Ugandan market while maintaining links to a wider East African dairy network.
Brookside’s ownership has long attracted attention because of its connection to Kenya’s powerful Kenyatta family.
The company is largely owned by members of the family of Uhuru Kenyatta, Kenya’s fourth president, and has grown from a local dairy processor into one of the region’s biggest milk companies.
Founded in Kenya in 1993, Brookside expanded through acquisitions, building operations across East Africa and becoming a dominant player in dairy processing.
A July 2025 company filing lists Muhoho Kenyatta, the brother of former President Uhuru Kenyatta, alongside John Stuart Armitage and Paolo Maria Tafuri as directors of Brookside Limited in Uganda.
The company’s expansion reflects a broader trend in East Africa, where family-owned conglomerates have used acquisitions and regional integration to build powerful business networks.
The tax waiver comes at a time when governments across the region are under pressure to increase domestic revenue collection and reduce dependence on external financing.
Tax exemptions and write-offs have often been justified as tools to support investment, protect jobs or resolve long-standing disputes between businesses and revenue authorities.
However, the absence of details surrounding Brookside’s tax arrears leaves unanswered questions about why the debt qualified for cancellation and whether similar relief is available to smaller businesses facing tax difficulties.
For Uganda, the Brookside case represents more than a single corporate tax decision. It highlights the continuing challenge of managing the relationship between government, foreign investors and powerful regional companies while maintaining confidence in the fairness of the tax system.
As East Africa’s economies compete for investment, the question remains whether tax incentives and debt forgiveness create sustainable growth — or whether they risk creating unequal treatment between large corporations and ordinary taxpayers.
You can see the list of Taxes Ugandans Started Paying last month Here.
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