Edgar E. Mugarura

background

Edgar is an Associate with the Corporate Advisory and Tax teams at ALN Uganda | MMAKS Advocates. He advises clients in various sectors such as insurance, private equity, banking and finance, manufacturing, transport and logistics and real estate on regulation, corporate restructurings, capital markets, and tax among others. He also undertakes corporate filings on their behalf regularly. 

Edgar is an Advocate of the High Court of Uganda and holds a Second Class (Upper) Bachelor of Laws degree from Makerere University, a Post Graduate Diploma in Legal Practice from the Law Development Centre and is a candidate for the Diploma in Tax and Revenue Administration from the East African School of Taxation. 

MEMBERSHIP IN PROFESSIONAL SOCIETIES

• Uganda Law Society
• East Africa Law Society 

PROFESSIONAL QUALIFICATIONS

2022                      Advocate of the High Court of Uganda

2021                       Post Graduate Diploma in Legal Practice, Law Development Centre

Career summary

2024 to date         Associate, MMAKS Advocates

2022 – 2024              Legal Trainee, MMAKS Advocates

2020 - 2022               Legal Assistant, Cristal Advocates

areas of expertise

• Corporate and Commercial Transactions
• Tax

TOP matters

TAX 

• Advised Greenwheels Electric Mobility Solutions Limited, a managed electric mobility fleet provider, on the tax and commercial structuring of its e-bike leasing and on-demand passenger and cargo hailing model.
• Advised Arcride, an electric mobility solutions company on the tax and commercial structuring of its electric motorcycle operations, including asset ownership and leasing arrangements, rider engagement models.
• Provided tax advisory support to Tetra Pak a global food processing and packaging solutions company in connection with its proposed expansion into Uganda.
• Advising Louis Dreyfus Company Uganda the local arm of Louis Dreyfus Company (LDC), a leading global agricultural commodities merchant and processor operating across the value chain from farm to market on tax and commercial matters relating to its Ugandan operations and expansion.
• Advised Sun King, a global off-grid solar energy company providing pay-as-you-go solar and energy access solutions across Africa, on stamp duty matters arising from its Ugandan operations, including review of transactional documents and financing arrangements, assessment of the applicability and valuation basis for stamp duty under Ugandan law, and support in preparing and prosecuting objections to stamp duty assessments issued by the Uganda Revenue Authority.
• Advised the United Nations Federal Credit Union (UNFCU) in connection with its Uganda Representative Office on matters relating to its income tax status, and provided support in reviewing and responding to an income tax assessment issued by the Uganda Revenue Authority (URA).
• Advised the Digital Economic Group (DEG) on the applicability of Uganda’s Digital Services Tax (DST) to its members’ digital platform operations, including analysis of whether the members’ business models and revenue streams constituted taxable digital services under Ugandan tax law, assessment of nexus, user location, and payment flows for DST purposes, and evaluation of registration, filing, and compliance obligations; provided technical guidance on the interaction between DST, income tax, and withholding tax regimes.

CORPORATE ADVISORY 

• Advising the Office of the Auditor General on the special audit of UMEME Limited lease of the electricity distribution network. This entailed a review of the Lease and Assignment Agreement, Support Agreement, Power Purchase Agreement and Escrow Agreement to advise on the processes, notifications and consents triggered under the agreements upon expiry of the lease to UMEME Limited, the determination of the buyout amount payable by Government of Uganda and the respective obligations of the Government of Uganda and UMEME Limited.
• Advising the Office of the Auditor General on the special audit of Pader-Abim Community Multipupose Electric Cooperative Society Limited (PACMECS) entailing review of contracts, agreements and licenses associated with the lease of assets to PACMECS by UEDCL (“PACMECS Lease”) as well as the operations of PACMECS and prepare a legal report advising the Auditor General on the consequences of the termination of the PACMECS lease, the processes, notifications and consents triggered by the transfer and takeover of the PACMECS lease; and the obligations of the Government of Uganda and PACMECS upon the termination of the PACMECS Lease.
• Advising the National Planning Authority on the feasibility study for student and staff accommodation PPP projects for four universities (Busitema, Mountains of the Moon, Soroti, and MUBS), conducting full legal due diligence and advisory work on feasibility, compliance, and structuring, and supporting procurement, contract drafting, and negotiations in line with PPP laws and institutional mandates.
• Advising Mirai General Insurance (Uganda) on the sell of the entire shareholding in the Company by the shareholders valued at USD 1,609,359 to a new investor, Pride Global Holdings Pte Limited and the subsequent increase in share capital of the Company to UGX 12,000,000,000 to comply with the Capital Adequacy Ratio requirements set by the Insurance Regulatory Authority. 
• Advising Jumo World Limited Group the ultimate parent company of the Jumo Group, a financial services group with subsidiaries in various jurisdictions including Uganda on its proposed restructuring. The restructuring would result into creation of a new entity that would become the new ultimate parent company for the Jumo Group whilst leaving the ownership of the subsidiaries unchanged. Our advice entailed advising on the potential regulatory impact of the transaction on already held licences in Uganda. 
• Advising African Frontier Capital on a transaction involving a private warehouse transaction in Uganda. The transaction entails the Uganda private warehouse company selling the receivables arising from Ugandan-law governed customer contracts to a new Special Purpose Vehicle. The SPV would in turn fund the purchase of propducts sold by the Ugandan private warehousing company through loans advanced to it by Development Finance Institutions. 
• Advising a global manufacturer and exporter of tobacco products on the legal regime governing the importation of tobacco products in Uganda. 
• Advising ADP a global payroll services provider on its new product. The product entails ADP partnering with a payment partner to facilitate payroll and other payment processing on behalf of ADP clients. Our work entail advising ADP on the regulatory regime of payment systems and highlighting any regulatory restrictions that would impede the operation of the product. 
• Advising a fuel marketing company on its introduction of a cross-border fuel card. The company intends to commercialize a cross-border private fuel card to professional customers of the network of gas stations operated in different jurisdictions including Uganda. 
• Advising Flutterwave Inc, a financial technologies firm on its acquisition of National Payments Systems licences from Bank of Uganda.