TRA had disallowed TBL’s input tax claims because many invoices did not comply with the strict requirements of the Value Added Tax Act, 2014
Dodoma. Tanzania Breweries Limited Plc (TBL) has suffered a major setback in its long-running tax battles after the Court of Appeal upheld a Sh6.53 billion assessment by the Tanzania Revenue Authority (TRA), even as the company secured a reprieve in a separate dispute over filing delays.
In a decision delivered on Thursday, September 4, 2025, a panel of three justices, M.C. Levira, L.L. Mashaka and D.J. Nangela, dismissed TBL’s challenge against TRA, affirming that the brewer must pay Sh4.88 billion in principal value added tax (VAT) and Sh1.65 billion in interest for the period between April 2016 and December 2017.
TRA had disallowed TBL’s input tax claims because many invoices did not comply with the strict requirements of the Value Added Tax Act, 2014.
The authority said a large number of the documents, some issued manually, lacked mandatory details such as the customer’s name, address, Tax Identification Number (TIN), and VAT registration number.
TBL countered that the rejection was unfair, citing technical issues with Electronic Fiscal Devices (EFDs) and arguing that substantive compliance should outweigh missing formalities.
However, the Court sided with TRA, stressing that only fully compliant tax invoices or fiscal receipts could support claims for input VAT deductions.
“The evidence is the tax invoice generated by the EFD or a fiscal receipt containing the name, address, TIN, and VAT registration number of the customer,” the justices ruled.
The decision effectively seals the brewer’s liability for over Sh6.5 billion, underscoring the taxman’s insistence on strict compliance with invoicing standards.
On the same day, however, TBL earned some breathing space in another tax case.
Justice L.A. Mansoor granted the company a 14-day extension to file its appeal against a June 2024 ruling by the Tax Revenue Appeals Tribunal (TRAT), which had also ruled in favour of the TRA.
TBL had filed a notice of appeal but failed to lodge the record in time due to flaws in the Judiciary of Tanzania’s Online Filing System (JoT-eCMS), which was not configured to accept appeals originating from TRAT.
Attempts to file manually at the Dar es Salaam sub-registry also failed because staff had travelled to Dodoma for the inauguration of the Judiciary Square.
TRA, represented by Senior State Attorney Athuman Mruma, argued that the brewer had been negligent by waiting until the deadline to file.
But the Court accepted TBL’s explanation, noting that the company had prepared the record well in advance and supported its claims with affidavits, system logs, WhatsApp messages, and testimony from a judicial IT officer.
“The flaws in the electronic filing system constituted sufficient reason for the court to exercise its discretionary powers,” ruled Justice Mansoor.
The extension gives TBL another chance to contest a significant tax liability in what is shaping up to be one of the most closely watched corporate tax battles in recent years.
Together, the two rulings highlight both the growing importance of electronic systems in Tanzania’s judiciary and the high stakes facing multinational companies operating under tightened tax enforcement.
