Raising local authority district revenues through direct taxation in a low-income developing country: evaluating Uganda's GPT

Raising local authority district revenues through directtaxation in a low-income developing country:

evaluating Uganda's GPT

IAN LIVINGSTONE1 and ROGER CHARLTON2*1University of East Anglia, Norwich, UK

2Glasgow Caledonian University, UK

SUMMARY

Uganda's graduated personal tax represents a rather unusual attempt at applying a localincome tax as a means of ®nancing local authority operations in a predominantly informal,rural economy. Statistical and other analysis and comment reveal it to have serious de®cienciesin terms of standard tax criteria and as a result of associated social costs, despite which localauthorities have been led to increase rather than to decrease their reliance on it. Somealternative revenue-raising instruments which could serve to reduce this reliance are indicated.# 1998 John Wiley & Sons, Ltd.

INTRODUCTION

Decentralization of government and of government ®nancing is an importantobjective in many developing countries. Local or district government authorities havean advantage in being able more closely to identify people's needs and thus to supplythe appropriate form and level of services and can be more closely held responsible bylocal communities for the provision of such services. In turn communities are morelikely to be willing to pay taxes locally where the amounts they contribute can berelated more directly in their eyes to services received. As a result the level of taxrevenue raised without excessive public dissatisfaction may be increased.

Raising taxes in most developing countries, especially those with large agriculturalsectors, however, is in general problematic and encounters a number of obstacleswhich together produce what is referred to as `low taxable capacity'. Uganda'seconomy is typical in this regard, with a predominantly peasant or smallholder farmeconomy and mostly informal trade, transport, construction and service sectorspopulated by small enterprises which frequently do not maintain accounts which canbe usefully checked by tax authorities. In this context it is particularly di�cult toapply direct taxation of incomes, especially in the districts, where formal sectoremployment is likely to be quite limited. The revenue-raising problems associated

CCC 0271±2075/98/050499±19$17.50# 1998 John Wiley & Sons, Ltd.

PUBLIC ADMINISTRATION AND DEVELOPMENT

Public Admin. Dev. 18, 499±517 (1998)

*Correspondence to: R. Charlton, Department of Social Sciences, Glasgow Caledonian University,Cowcaddens Road, Glasgow G4 0BA, UK.

with decentralization of government where the economy is predominantly rural aredescribed by Parker (1995):

Speci®c economic conditions in rural areas also result in fewer developmentopportunities being available than in non-rural locations. Agriculture isgenerally the most important economic sector, making rural areas highlydependent on the performance of a single sector, where investmentsare risky. In addition, the tax base is limited, resulting in rural areas oftenbeing unable to mobilise su�cient resources to ®nance their own RD [ruraldevelopment] programmes (p. 1).

The lack of adequate funding for lower-level governmental institutions was citedas `the single most important factor' that undermined many decentralization pro-grammes in the 1970s (Cheema and Rondinelli, 1983).

Notwithstanding, Uganda, unusually, has a long history of attempting to raiselocal tax revenues through a form of direct taxation, what is now called GraduatedPersonal Tax (GPT). This is a personal tax levied on all males aged 18 and over,1

together with females engaged in business. A number of modi®cations of the tax havebeen made over the last two decades in particular, in an e�ort to make it moreprogressive and relate this local tax contribution more directly to the level of incomessecured by individuals in rural and urban areas across Uganda while developing italso as the foundation for local authority revenues. Given the programme of ®nancialdecentralization which has been pursued by the Uganda Government since theprogramme's inauguration in October 1992, this role is of particular signi®cance. Inthis article we comment only rather brie¯y on alternative tax sources which might bedeveloped and concentrate on relating something of the experience with this relativelyunusual tax, the GPT.

THE HISTORICAL BACKGROUND OF GRADUATED PERSONALTAX IN UGANDA2

The origins of GPT go back to Hut Tax, introduced by the colonial government in theHut Tax Regulations of 1990, and to the poll tax introduced by ordinance in 1905.These were collected on behalf of the Native Authorities by chiefs who could retain aportion of the revenues. Later, in 1938, a ¯at rate African administration tax wasintroduced.3 During the 1950s, district councils in most parts of Uganda introducedhypothecated education taxes on individuals in addition (Davey, 1974, p. 35).

A poll tax is, of course, the most regressive of taxes. The Wallis Report of 1953recommended the introduction of graduation, both as a means of increasing yield andto take account of obviously signi®cant strati®cation of rural incomes. This wasaccepted (though not the abandonment of an existing Shs 6 poll tax) and introducedprogressively from 1954 in di�erent districts, ®rst under the existing African Admini-stration Tax Ordinance and from 1955 under the District Councils Ordinance.Throughout, Government maintained a ceiling of Shs 400 in order to protect its own

1Excluding those speci®cally exempt on grounds of health, those registered as full-time students and thosein the Army or Police.2This section draws heavily on Davey (1974).3This replaced an earlier tax, luwalo, introduced in 1925.

500 I. Livingstone and R. Charlton

# 1998 John Wiley & Sons, Ltd. Public Admin. Dev. 18, 499±517 (1998)

income tax sources, a ceiling still re¯ected, for the same reasons, in the current GPTlimit of Shs 80 000 (US$80). In January 1963, immediately prior to independence, allpoll taxes were abolished and all races made subject to a common system of CentralGovernment income tax and Local Government graduated tax.

With decentralization as a central part of its national development policy, thecurrent (Museveni) Government in Uganda has been interested in all potentialsources of government revenue, including GPT, which can be tapped at the districtand municipal levels in order both to provide the ®nancial basis for decentralized anddemocratized decision-making and also to reduce dependence on central governmentfunds which are in short supply.4 Interestingly, a similar idea was pronounced by thethen Governor, Sir Andrew Cohen (Cohen, 1954, p. 32), in 1954, who stated that:

It is obviously important that the district councils should develop andincrease their own revenue, and transferred services [such as primaryeducation, veterinary and agricultural ®eldwork, and public health] shouldnot have to be ®nanced mainly by Government grants.

He went on to say (p. 32) that:

It is therefore encouraging that most of the [district] councils have alreadyeither imposed or agreed to impose graduated tax . . . Graduated tax hasnot always been acceptable to public opinion in Africa, and it will beextremely interesting to see how the new system works.

One issue which was discussed at di�erent times in the early 1960s is whether GPTshould be based on income or on assets, `the value of visible possessions'. As Daveystates (p. 40), one reason was the desire (desire also by councils, which needed therevenue) to cover both farm income and wages and salaries, in addition to the viewthat potential cash earnings from assets provided the most appropriate measure ofcapacity to pay and the fairest basis for tax assessment.

The current GPT still uses persons as its tax base: all men over 18 should pay thetax and carry a tax certi®cate (`ticket') on their person, as well as all women over 18who are gainfully employed. Payment is made to the local government in the districtor urban council area in which the person is resident. With the aim of providingconsistency across districts, the Ministry of Local Government provides detailedvaluation procedures which districts should follow, and tax rates to be applied toassessed income; however, districts use their own discretion in making actual assess-ments (made by the sub-county) of a person's income, which, as shown presently,produces wide variations in assessment patterns. In the case of persons in formal (notinformal) sector paid employment, GPT is withheld by the employer, creating asigni®cant di�erence between tax collections in the urban and district council areas.

A major review of GPT in 1983 was conducted by Muwanga-Zake (1983).5 Hisproposals, which were accepted, aimed to develop GPT more systematically as a localincome tax, introducing a stronger element of progressivity and equity into the tax byincorporating a large number of tax bands, 26 up to 1992±1993, later increased to 37,

4In 1996 the Ministry of Local Government commissioned a comprehensive report on Enhancing DistrictRevenue Generation and Administration (ODA, 1996).5Reference may be made here also to the Report of the Commission of Inquiry into the Local GovernmentSystem (Republic of Uganda, 1987), which considered GPT in some detail, identifying numerous de®cien-cies but ultimately recommending its retention as a staple revenue source.

Evaluating Uganda's GPT 501


and proposing the use of detailed, comprehensive inventories of households' produc-tive assets as a basis for estimated annual monetary and non-monetary income onwhich the assessed tax would be based, using ìmputation values' to cover marketedand non-marketed products. This use of ownership of productive assets to derivepresumed income introduces an element of wealth tax in the assessment alongsideordinary income elements. The imputation values are still given for ®ve zones only(Eastern, Western, Northern, South-West and Buganda) rather than on a detailedbasis for districts, for both major crops such as co�ee and minor crops such as ginger,and for all livestock, including three categories of chickens. For urban formal andinformal businesses a detailed system of secured income values is hypothesized,covering each of the commodities handled (see ODA, 1996, Appendices L and M).Here the assessor simply makes a judgement regarding the income that a particulartype of enterprise in a given location can be expected to make, from knowledge of theneighbourhood.

Despite these changes, the tax remained unpopular and was discussed at somelength in the course of the o�cial Commission of Inquiry into the Local GovernmentSystem, widely referred to as theMamdani Commission after its Chairman, the reportof which was published in June 1987. The Commission gave serious consideration toabolishing the tax, identifying numerous de®ciencies, but ultimately recommended itsretention as a staple revenue source for local governments. As the report states, on thebasis of submissions received ànd because graduated tax is such a vital part of thepresent revenue of local authorities, we dropped any suggestion that it be abolished'(Republic of Uganda, 1987, p. 98).

Dissatisfaction continued to smoulder, with several open disturbances, particularlyriots in Iganga, which were investigated by a Ministry of Local GovernmentCommission of Inquiry in 1994. Its report (Republic of Uganda, 1994), whilst under-lining the point that GPT still evoked `the old primitive interpretation as opposed tothe positive one of [a] resource for development', also indicated that taxpayerresentment of GPT was increasing and spreading'. The Commission also wishes toobserve that while Graduated Tax rejection has a long history in the Eastern part ofUganda, particularly in Iganga and its neighbouring districts, it has neverthelessbecome national as it has spread to other Districts of Uganda and consequently theGovernment has to look at it in that context' (Republic of Uganda, 1994, p. 5).

The tax continues to be the subject of active debate and press comment. In August1996 an MP raised the question in Parliament whether it was still worthwhile forGovernment to continue collecting the tax, suggesting that other ways of collectingrevenue should be sought because `GT was an impediment to modernization'. Theeditor of The Monitor (16 August 1996) was even more forthright: `Musolo is useless;just get rid of it. Graduated tax (musolo) is a primitive tax which should be got rid of. . . Most of the graduated tax is spent on the thousands of people who collect it, andsteal it along the line up to the top. Graduated tax makes economic nonsense, and it isa social disaster. Because it's the poorest of the poor in the villages who can't a�ord it,they are humiliated further, as they have to hide and spend nights in the bushes tokeep away from brutal collectors'.

Analysis of the tax formed part of a study of possibilities for district revenueenhancement carried out by the ODA in 1996 on behalf of the Ministry of LocalGovernment (ODA, 1996). This report was followed up in 1997 by a comprehensivestakeholder workshop organized by the Ministry to bring together key personnel



from across local and central government institutions for discussion of issues relatingto local authority revenue enhancement and administration (DFID, 1997), at whichGPT was again debated at some length. Reform of the local taxation system,including GPT, is thus high on the current political agenda in Uganda while, asalready stated, Uganda's speci®c and prolonged attempts to apply a satisfactory localincome tax within a largely ìnformal' rural economy are of wider interest.

Despite past problems and continual criticism, the tax has proved to haveremarkable resilience, largely owing to a combination of familiarity and the absenceof an immediately obvious, or politically immediately feasible, alternative revenuesource and additional tax base available to local governments. GPT now represents abasic revenue source for district and municipal governments. District councils have analmost overwhelming dependence on it, to the extent of 61±89 per cent in 1993±1994(Table 1) and as much as 40 per cent in the case of some municipalities, includingKampala. In Kampala, dependence on GPT relative to other income sources hasincreased dramatically since 1991±1992 (Livingstone, 1997) as a result of a slow andine�ective approach to property tax assessment and collection, despite its hugepotential in Kampala. Whatever the inadequacies and inequities of GPT as a tax,Kampalas's increasing reliance re¯ects the relative ease of collecting revenue from it ina capital city with a rapidly expanding urban population and containing a large

Table 1. Distribution of actual council revenues by source, 1993±1994 (%)

CouncilGraduated

tax MarketsTaxi, busparks

Trade, otherlicencesand fees Property

Housing,rent Othera

MunicipalitiesKampala 40.2 11.3 6.9 11.9 16.4 7.2 6.1Jinja 14.0 13.1 7.8 4.7 28.0 11.4 21.0Mbaleb 21.5 52.3 5.5 20.0 ± 0.7Fort Portalb 27.1 34.8 ± 18.4 15.5 ± 4.3Gulu 19.0 36.5 6.4 3.6 2.1 18.8 13.6Bushenyi 40.7 13.3 20.4 5.3 ± 2.7 17.7Mukono 36.0 18.0 14.9 11.2 8.1 ± 11.8Tororo 22.1 40.7 14.7 8.8 13.2 ± 0.5Njeru 32.1 8.8 ± 5.0 5.0 15.7 33.3Kitgum 18.3 29.0 ± 4.3 ± 14.0 34.4

DistrictsMbale 61.7 13.4 ± 14.6 ± 0.1 10.3c

Kabarole 57.6 13.6 ± 8.4 ± 0.2 20.2c, d

Gulu 73.6 22.4 ± 3.0 ± 0.3 0.7Bushenyi 73.5 ± ± 13.0 ± 0.3 13.3Luwero 71.0 26.2 ± 2.6 ± ± 0.2Mukono 73.1 22.7 ± ± ± ± 4.2Mubende 66.2 8.5 ± ± ± 0.3 25.0Tororo 88.9 4.9 ± ± ± ± 6.3Iganga 74.4 6.4 ± ± ± ± 19.2Masaka 84.9 11.3 ± ± ± 0.1 3.7

aExcludes transfers from Central Government.bPercentages based on estimates, not actual values.cIncludes education tax.dIncludes kibanja fees, a head tax levied on squatters.



proportion of taxpayers who pay GPT at source out of wages and salaries. About 60per cent of collections in Kampala are through PAYE.

EFFECTIVENESS OF GPT AS A TAX

GPT can be evaluated as a tax according to the usual criteria, starting with fairness orequity, both vertical, in terms of falling proportionately more heavily on those withhigher incomes, and horizontal, in terms of falling equally heavily on those withsimilar levels of income. GPT performs poorly in both these directions. Although theMuwanga-Zake review of 1983 introduced a large number of bands, with precisely theobjective of incorporating a substantial degree of progressivity, this progressivity doesnot materialize in practice. No exemptions are allowed, even at very low incomes,so that tax liability begins at Shs 2 000 (about US$2) for assessed incomes belowShs 24 000 p.a. up to a ceiling of Shs 80 000 in tax operative for assessed incomes ofShs 821 000 and over. The large number of grades means that the average band size isonly Shs 2000±3000, about US$2±3. In terms of the announced rates, progressivityexists in absolute terms, but in percentage terms the tax is regressive from an initialrate of 9.4 per cent at assessed income of Shs 32 000 to 5.7 per cent at Shs 330 000,subsequently rising very gently towards only 9.7 per cent at Shs 821 000.

The actual progressivity or lack of it, however, is determined by the manner inwhich assessments of income are made rather than by the announced rates for eachlevel of income. Overall, in 1992±1993, for instance, 75 per cent of GPT payers fellwithin the ®ve tax grades out of 37 covering the assessed income range Shs 40 000±120 000 out of the full range Shs 0±820 000 (Table 2). In Kampala, 70 per cent were inthe bottom two grades, covering assessed income of Shs 70 000±110 000, e�ectively apoll tax of US$6±7, despite the actual wide spread of incomes which would be

Table 2. Distribution of rural graduated taxpayers in Uganda compared with distribution ofrural households by per capita household income, 1992±1993

Monthly per capitaincome class(Shs000)

Distribution ofhouseholds

(%)Graduated tax payable

(Shs000)Distribution of payers

(%)

0± 63.6 2 15 1.2 1.210± 26.6 3 16 4.5 0.920± 6.3 4 17 9.3 0.930± 1.9 5 18 22.8 1.040± 1.0 6 19 21.6 1.060± 0.3 7 20 12.6 1.180± 0.2 8 21 9.2 0.1100± 0.1 9 23 4.4 0.1200 or over 0.1 10 25 3.5 0.2

11 27 1.2 0.112 30 1.7 0.213 35 1.2 0.114 40 1.0 0.2

Source. National Integrated Household Survey (household data), Ministry of Local Government (taxdata).Note. In 1992±1993 there were just 26 tax bands.



expected in what is a large urban economy (Table 3). It may be observed speci®callythat while 30 per cent of taxpayers were above the two bottom grades, 68 per cent ofhouseholds were above the bottom two income grades: the dispersion of householdincomes is not re¯ected in the narrow range of tax assessments.

A particular source of dissatisfaction with GPT as presently in operation is theexistence of a ceiling at a tax of Shs 80 000 (income of Shs 821 000 and above) whichappears to protect the very rich. This implies no change in the amount of direct tax,local or national, between incomes of Shs 821 000 and Shs 1 500 000, the approximatelevel at which central income tax becomes operative. Over this range the tax rate thusfalls from 9.7 to 5.3 per cent. To counter this, and to remove regressivity, at least atlower levels of income also, removal of the ceiling and application of a ¯atproportionate rate have been recommended by other observers (Nelson, 1994; Bahl,1996, p. 29; Mahler et al., 1997). Abolition of the ceiling would increase fairness ofpayment above incomes of Shs 820 000, at least for those in paid employment, but notwithin the whole range below that where the inequity arises out of assessment ratherthan out of announced rates. Among rural taxpayers, for example, it would still haveleft in 1992±1993 less than 6 per cent of payers assessed within the 17 bands coveringincomes of Shs 160 000±580 000.

How far the tax as a whole is directed towards the bottom of the income distribu-tion is even more evident when its incidence is measured against a welfare measurerecently calculated by the World Bank (1995). This calculates the ratio of householdexpenditure per adult equivalent to a speci®ed poverty level. On this basis the bottom61 per cent of the Uganda population are classi®ed as poor (Table 4). The expend-iture of the bottom quarter, who comprise the bulk of the GPT taxpayers, amounts tojust over half the poverty level.

Graduated tax is de®cient also from the point of view of horizontal equity. Despitethe comprehensive and detailed methods of assessment now o�cially sanctioned, andthe centrally set rates, assessments of income and therefore actual payments of tax arerevealed by available data to be extremely arbitrary. Thus in 1992±1993, in a selectionof District authorities (Table 5), the mean value of GPT assessments varied fromShs 3 121 in Kisoro to Shs 10 784 in Mubende. The distribution of GPT payers over

Table 3. Distribution of graduated taxpayers in Kampala City compared with distribution ofhouseholds by per capita household income, 1992±1993

Monthly per capitaincome class(Shs000)

Distribution ofhouseholds

(%)Graduated tax payable

(Shs000)Distribution of payers

(%)

0± 6.9 6 17 44.5 0.610± 24.9 7 18 25.2 0.520± 24.2 8 19 7.0 0.330± 14.1 9 20 3.1 0.840± 11.5 10 21 3.2 0.460± 6.8 11 23 1.6 0.380± 5.2 12 25 1.1 0.4120± 3.2 13 27 1.2 0.5100± 1.8 14 30 0.9 0.5200± 2.2 15 35 1.0 0.5300 or over 0.1 16 40 0.5 4.6

Source. As Table 2.



the range has also varied widely between districts and bore no relation to the level ofrural incomes in di�erent districts. Thus in a comparatively well-o� district such asIganga over 50 per cent of payers paid Shs 4 000 or less, compared with only 8 percent in Lira, which is much poorer. In Lira the majority, 86 per cent, paid betweenShs 7000 and Shs 12 000.

The ®gures for urban authorities are a�ected by those for Kampala, which are verydi�erent from the rest. Surprisingly, the mean payment for urban authorities otherthan Kampala and Jinja was Shs 6420, compared with Shs 7200 for rural authorities,although incomes in urban areas, at least in money terms, are much higher than thosein rural areas. Moreover, just over 40 per cent of these urban payers are in the lowest

Table 4. Distribution of economic welfare in Uganda

Distributionpercentiles

Welfare measure(highest value in each percentile)

99 4.64395 2.51090 1.91675 1.28961 1.00050 0.85025 0.55910 0.3815 0.3001 0.193

Source. World Bank (1995), calculated from the 1992±1993Integrated Household Survey.

Table 5. Distribution of graduated tax payers by tax band for selected rural and urbanauthorities, 1992±1993

Local authority

Proportion (%) of payers falling in tax bands (Shs) Meanpayment(Shs)2000± 5000± 7000± 13 000± 27 000±40 000

DistrictsMubende ± 8.8 68.6 21.5 1.0 10784Kiboga ± 4.4 80.0 13.1 2.5 10659Lira 1.6 6.7 85.8 5.1 0.9 8458Mbarara 7.2 30.5 55.2 5.3 1.8 8066Mukono 20.0 66.1 12.4 1.3 0.1 6383Mpigi 9.2 67.5 29.5 3.0 0.8 6375Mbale 1.2 86.0 12.6 0.2 0.1 5701Iganga 51.5 43.1 5.1 0.3 (..) 4638Kisoro 42.6 32.0 25.0 0.4 ± 3121

All rural 14.8 43.9 32.1 8.6 0.5 7200

UrbanKampala ± 45.1 41.6 7.2 6.1 10463Jinja 31.7 48.3 13.3 4.5 2.3 6306

Other urban 41.1 30.8 19.9 6.4 1.8 6420

Source: Ministry of Local Government data. (..) � negligible ®gure.



bands, paying Shs 2000±4000, compared with only 15 per cent in the rural areas.Even in Kampala, 45 per cent fall within the Shs 5000±6000 bands compared withonly 4±9 per cent in Kiboga, Lira and Mubende. Graduated Tax therefore appears tobe ùnfair' in two senses: unfair in not being closely related to income and unfair inbeing unequal or arbitrary in its incidence on similar income recipients.

Its lack of relation to actual taxpayer incomes is revealed by the data in anotherway. Taking Mbale as an extreme example, 86 per cent of payers paid Shs 5000±6000.This clearly bears no relation to the actual distribution of incomes and would indicatethat this level of payment has come to be accepted as `the norm' by both payersand collectors, operating in e�ect as a poll tax. This also indicates that the o�cialassessment procedures involving close calculation of money incomes are not beingfollowed. Di�erent levels may also re¯ect di�erences in perceived (by collectors or theauthority) di�erences in willingness to pay, low, for example, in Iganga and high inLira, irrespective of income levels.

Problems of GPT collection, particularly where the population is dispersed across awide area (as well as where the district is poor), also mean that the proportion of thoseeligible actually paying the tax is well below the target level. If one takes the rural malepopulation aged 20±59 as approximating the tax base (excluding women payersand those eligible outside this age range), only four districts achieved coverage of80 per cent or more in 1993±1994 and 10 out of 24 districts (listed in Table 6) achievedcoverage of 50 per cent or less. Overall, of all eligible taxpayers aged 18 and over, about60 per cent pay. Apart from questions of administrative e�ciency, to be examinedpresently, this coverage again implies a major degree of inequity between those whopay and those who succeed in evading the tax. Thus, despite the long experience withthe tax and the degree of acceptance by the population which has been gained, theoriginal problems of coverage remain to a signi®cant degree.

As just indicated, a second `canon' of taxation is administrative e�ciency, therevenue secured from a tax relative to its costs of collection and administration.Enumeration of taxpayers and assessment and collection of GPT are each majoradministrative exercises which occupy an àrmy' of people annually in each districtover a period of some three to four months. The use of 37 narrow bands or divisionswithin what is a relatively narrow range of incomes means that very detailed data onhousehold incomes are required. As set up, this includes data on all farm output,marketed and non-marketed, as well as on non-farm activities in the rural informalsector. Proper assessment, given major year-to-year variations in income, requiresthat this be collected annually in every sub-county in Uganda for all households. Theamount of information called for if this is carried out accurately is as detailed aswould be involved in a comprehensive national farm survey of the type contemplatedonly at periodic intervals, if at all: even Uganda's Agricultural Census of 1991 wasexecuted on a sample basis. The reality is that assessments are mostly arbitrary, ofteninvolving `desk' methods of assessment, apart from problems of collusion betweenpayers and assessor, favouritism and political in¯uence.

Collection of GPT involves a massive exercise conducted annually over a three-month period and involving a substantial workforce. Collection costs are very heavy,especially in the Districts, and may exceed 30 per cent of the tax collected in somecases, though they are much lower in the Municipalities. In the Districts, poor com-munications and lack of transport make control by District Councils over collectionsby sub-counties practically impossible. Speci®c collection cost data were obtained



for both Mbale Municipality and Mbale District Council. In the former case, costsof all kinds, including wages and allowances of enumerators and collectors, wereabout Shs 39mn in 1994±1995 compared with revenue of Shs 122 mn, equivalent to32 per cent. In the latter, costs at District HQ were about Shs 13mn and at sub-county level were Shs 20 mn for mobilization and about Shs 120 mn for admini-stration, altogether amounting to just under Shs 153 mn, compared with revenue ofShs 686 mn, equivalent to just over 22 per cent (ODA, 1996, para. 5.6.8). Earlier®gures for administrative sta� costs in relation to tax revenue collected presented inthe Iganga Tax Riots Commission of Inquiry Report indicate considerable variabilitybetween districts, ranging from 248 per cent to 13 per cent across a sample of 11districts in FY 1992±1993 (Republic of Uganda, 1994, p. 52). This enormous inter-district variation becomes more credible if it is interpreted in the light of thecomparably large di�erences between districts in their ratios of administrative sta� totaxpayers, ranging from 1:26 up to 1 :347 in a sample of 16 districts for the same®nancial year (Republic of Uganda, 1994, p. 34).

A third criterion for a good tax, in the context of development particularly, is that itshould be revenue-elastic, so that tax revenue rises automatically as income levels rise,without requiring adjustment of tax rates. From what has been said already, it isevident that GPT does not perform well here either. The rates themselves are ®xed

Table 6. Ratio of rural adult male population to number of graduated tax payers by district,1993±1994

District RegionaNo. ofpayers

Rural malepopulationaged 20±59b

Ratio of payersto population

(%)

GT revenue (Shs)

per payer per male

Mpigi C 132255 138275 95.6 10300 9842Nebbi N 43704 49880 87.6 7610 6670Mukono C 111940 129969 86.1 9010 7764Iganga E 126806 156947 80.8 7160 5782Kiboga C 18812 24931 75.5 15370 11592Kapchorwa E 15000 20087 74.7 5330 3983Kasese W 39100 52909 73.9 11060 8174Luwero C 53818 73603 73.1 12770 9340Masaka C 96247 134698 71.5 11600 8270Mbarara W 107696 155404 69.3 13100 9105Bundibugyo W 12966 19009 68.2 6990 4764Hoima W 23296 34709 67.1 13060 8767Kisoro W 19721 29610 66.6 7320 4874Kabarole W 80000 125492 63.7 7500 4781Lira N 42195 83531 50.5 13510 6824Apac N 39266 78547 50.5 11700 5854Pallisa E 30390 61552 49.4 7280 3598Mbale E 56464 116249 48.6 6810 3311Tororo E 40791 86364 47.2 11130 5256Moyo N 20256 49880 40.6 9390 6606Arua N 38490 105242 36.6 8420 3081Rakai C 18812 64885 29.0 15370 4454Soroti E 6056 66760 9.1 8280 750Kitgum N 2140 58988 3.6 7720 280

aC, Central; N, Northern; E, Eastern; W, Western.bCalculated from 1991 Census ®gures, applying national age ratios to District totals.



centrally and rigidly and are not adjustable by districtsÐalthough which bands areused by districts can vary. There is a ®xed ceiling, ®xed, moreover, at a low levelrelative to the lower limit of income tax liability, so that incomes can rise once theceiling is reached without any increase in tax contribution.

The ®xity of the rates, and of the ceiling, means that in¯ation erodes the real valueof the contributionsÐin Uganda this has been a�ecting all the local governmentrevenue sources so that, with irregular individual adjustments, the relative valuescontributed by di�erent sources have varied from year to year in an unplannedmanner (ODA, 1996). Most importantly, since the top income bracket has beenanyway left to contribute only a small percentage to the total, the manner of assess-ment has reduced GPT to operating very much as a poll tax, this by de®nition lackingelasticity.

As Bahl (1996, p. 28) notes, this inelasticity has encouraged local governmentsto make ad hoc adjustments, getting around the centrally determined tax rates,by shifting the base or piggy-backing onto GPT hypothecated surtaxes such as anèducation tax'.

SOCIAL AND POLITICAL COSTS OF GPT

Apart from its complicated assessment procedures and high collection costs, thereare, also under the heading of administrative e�ciency, considerable social andpolitical costs associated with the implementation of the tax in the form of harass-ment of the population, especially the relatively poor sections of the community,younger males and the unemployed or semi-employed. These costs need to be addedto the ®nancial costs of collection. The reports which follow are revealing. First a viewexpressed in a letter to a Sunday newspaper (S. Kamoga, Sunday Mail, 11 August1996) is worth reproducing:

The methods used by authorities in handling tax defaulters are deplorableand primitive. In Kampala City, people are waylaid on their way to work oron other journeys. If one is not carrying a ticket, he or she is doomed. Evenif one paid his tax but at that moment is not carrying the ticket, he isbundled onto a vehicle, his shirt removed and he is kicked or slapped. Thevehicle then heads to an unknown destination. Up country, the situation isworse. The defaulters are tied with ropes in the waists or necks like slaves.The Ministry of Local Government should use modern methods to handlethis since we are in the computer age and not in the Stone Age.

In relation to those who would have little capacity to pay, it was reported (TheMonitor, 16±19 August 1996) that:

Business in Mukono town was on August 9 temporarily paralysed as acombined force of armed LDUs [Local Defence Units] and Local Govern-ment law enforcement personnel mounted an early morning crackdown ongraduated tax defaulters. Over 300 youths, mainly brickmakers, boda bodamotorists,6 street children and idlers were netted. The tax men who were

6This refers to informal sector motorcycle and bicycle taxis.



deployed at strategic positions along the major roads, residential areasand footpaths as early as 4.00 am caught most residents unawares. Thosearrested were taken to Mukono Town Council o�ces . . . As more defaulterswere brought in relatives of some culprits were already paying to rescuethem.

Another newspaper report (The Monitor, 9±12 August 1996) stated that in HoimaDistrict: ìn villages, scores of peasants are having sleepless nights in bushes andforests due to fear of being netted over graduated tax'.

Uganda has received praise from multilateral agencies for its strenuous e�orts,within an overall structural adjustment programme, to improve the e�ectiveness ofits tax administration and to increase tax revenue. However, GoU attention, as wellas donor support, has focused on the development of the administrative structure ofthe national taxation system, essentially ignoring the capacity-building needs of itslocal government counterparts. To act as the spearhead for achieving improvementsin Central Government revenue performance, the Uganda Revenue Authority(URA) was established in 1991. Between 1991 and 1995, national revenue collectionsalmost quadrupled, with real annual increases between 16.9 and 18.6 per cent afterallowing for in¯ation (URA Final Report, 1995, pp. 11±12). Unsurprisingly, starvedof resources and with limited administrative capacity, local taxation administrationshave been tempted to adopt rather crude methods to achieve a doubling of theirtaxation revenues over approximately the same timescale. In the case of GPT, inparticular, the e�orts of local administrations to increase their revenues have oftenbeen too strenuous. One sub-county chief in Rukingiri District `shocked thegathering of about 300 people when he called upon armed Local Defence men tocome forward before them and ordered them to shoot to kill anybody who is in faultand may attempt to run away' (New Vision, April 1996). In April 1997, four taxadministrators were arrested following the beating to death of a defaulter. In anotherincident:

Shots were ®red, and 18 people critically injured on August 3, when a groupof armed tax collectors raided a wedding party in Hoima. The tax menraided a wedding at the home of Irumba Cornelius of Kasingo Village nearHoima town. Eyewitnesses [said] the tax men pounced at 3.00 pm, when thebagole (bride and groom) had just arrived and organisers were preparing toserve lunch to the invited guests. Sources said the 5 local Administrationcops led by PC Moses Barasa caused a stampede when they stormed theshade where the bagole and invited guests were seated. Barasa reportedlyordered all the people under the shade including the bagole to show himtheir 1996 Graduated Tax tickets. Many of those who did not have taxtickets panicked and ¯ed immediately. Pandemonium, however, broke outwhen angry defaulters fought back and Barasa and his men ®red severalshots in the air. The bagole and their guests scampered into the surroundingbushes and banana shambas . . . Scores of peasants lost their sandals, shoesand watches. The critically injured were rushed to Hoima Hospital in ablue pick-up. Only 2 defaulters, who were too drunk to run, were arrested(The Monitor, 14±16 August 1996).



The fact that all these cases were reported within a brief period of time indicates thescale and widespread nature of such events, most of which would not attract attentionin the national press.

CURRENT EXPERIENCE IN THE ADMINISTRATION OF GPT

At a recent workshop onDistrict Revenue Enhancement andAdministration attendedby representative district and municipal o�cials, GPT was a major focus of attentionand is discussed at length in contributions to the Workshop Proceedings (DFID,1997). Many practical problems in the implementation of the tax were noted, relatingto all stages of its application: registration, enumeration (of taxable assets), assessment(valuation of the derived income ¯ows presumed) and collection. Since the commentsrepresent the views of senior o�cers charged with the practical implementation ofGPT in the districts andmunicipalities, their observations areworth summarizing hereand can be taken to represent the situation with respect to GPT in 1997.

Problems with respect to registration

As can be deduced from the data provided earlier regarding the proportion ofdistrict populations paying tax, it is clear that the tax registers kept at the variousadministrative units are incomplete, usually substantially so. Registration is madedi�cult by the substantial migration, short- or longer-term, between rural and urbanareas, in search of employment, a�ecting registers in both places. In addition,individuals frequently change their employment, particularly in the informal sector,making it di�cult for collectors to track them down and determine their incomes forassessment. A speci®c problem in registration is that of `new entrants' reaching theage of 18, where there is also a problem of establishing age in the case of youngpersons, whose capacity and willingness to pay will be reduced by lack of income andin many cases employment. The registration of those women who are in business isdi�cult, since it is not straightforward to identify those in receipt of independentincomes.

Avoidance of registration (or enumeration) is a major preoccupation amongsections of the rural community referred to by a Kapchorwa-based o�cial as`perennial deserters'. Thus, to take Kapchorwa as an example, `large numbers ofpeople who ordinarily live in certain villages on the border with neighbouring Kenyamigrate toKenya during periods of property enumeration and tax assessment and onlyreturn to weed or harvest crops, or to do other business, including cultural festivities.They then go back to Kenya at the slightest indication and apprehension of taxdefaulters'. Amore unusual consequence, under the headline `Snake bites tax dodger',was the death reported in the press in 1996 of an individual who had successfullyavoided payment of tax for eight years, prior to encountering the snake, by jumpinginto bushes during the visits of tax o�cers.

The use of di�erent assessment rates for similar income categories betweenauthorities and di�erences in the imputation values used by district and urbanauthorities also lead to movement between areas in order to reduce liability,particularly along district boundaries.



The sheer size of some districts and the transport problems involved in reachingpotential taxpayers, particularly in areas of low population density, make coverage ofthe taxpaying population di�cult, in a few districts almost impossible.7 Geographicalfactors make it di�cult, for instance, to register or assess ®shermen who in someplaces do not have very ®xed places of residence8 as well as migrant livestock keeperswhere deliberate large-scale movement of already assessed taxpayers in MbararaDistrict is reported. This is related to a more general `cultural' aversion to enumera-tion of cattle among such communities.

However, there is the more common problem referred to by one o�cial as that ofthe `high class social defaulter'. Thus in one district, for example, there is stated to beà sizeable number of highly respected people, successful businessmen, opinionleaders and local political leaders and elders who either have never been on the taxregister or somehow have slipped o� the tax register in the process. Those who stillappear on the register simply and arrogantly do not pay and no one dare approachthem'. More than half the District Council members in this case were in full or partialdefault.

Problems with respect to enumeration and assessment

With respect to enumeration, there is reported à rampant tendency' amongst tax-payers to under- or non-declaration of assets, particularly the hiding of `movablewealth' such as livestock. A common practice is that of incorrectly listing propertyunder the names of absent relatives or friends.

A major problem is that enumeration is usually carried out over a four-monthperiod between June and September when neither the planting activities of thefarmers nor the eventual harvest outcomes are directly observable, resulting in eitherover- or under-assessment of income. An extreme case is that of the `disaster year' inagriculture. Such problems do not exist, of course, where indirect taxes onexpenditure are used.

An additional factor is that the imputation values used by assessment committeeshave been seriously out-of-date, the last set of values having been determined in1992±1993. Consultation with local o�cials to determine appropriate values indi�erent districts also appears to have been inadequate. The use of ®xed imputationvalues determined centrally is problematic, given constantly ¯uctuating prices foragricultural and livestock products.

Enumeration committees charged with visiting individual households are madeup of a combination of local political leaders, chiefs and technical personnel, the latterto assist in assessment and evaluation. This has not prevented the widespread exerciseof favour by chiefs for reasons of kinship, religious or other a�liation and offavouritism towards friends or victimization by political leaders and administrators. Inmany cases there is collusion between enumerator and taxpayer for mutual bene®t. Inparticular the possessions of rich taxpayers are usually grossly under-assessed, asborne out by the statistics provided earlier. As this suggests, there is a tendency to

7See the ®gures of 9.1 and 3.6 per cent for the ratio of taxpayers to rural male population in Soroti andKitgum respectively given in Table 6.8This has meant some sub-counties purchasing motor-boats to facilitate collection, increasing costs.



marginalize the technical sta� members in enumeration teams. Thus `the politicalleaders take a dominant role so that, as a result, assessment as carried out normallylacks the inputs of the experts who are meant to serve as their advisors'.9

In some cases, assessment is carried out by sub-county chiefs single-handedly or bythe LC Chairman alone, subjecting it to bias. Chiefs often work to speci®ed collectiontargets (as in the early days of graduated tax) under which the assessment proceduresare disregarded completely. Much more generally, however, a large proportion ofassessments are carried out as `desk' exercises despite the o�cial requirement to visitindividual households and enterprises directly, not surprisingly in view of the sheerimpossibility of visiting the number of households involved.

Business units are frequently grouped into classes without taking into accountactual individual income levels and the location of the enterprises, despite widevariations in income level. The usual lack of proper record-keeping among smallbusinesses is a further problem.

Problems with respect to collection

The actual collection of GPT raises another set of problems. One is that the timing ofGPT payment does not correspond to the harvest period of major cash crops suchas co�ee. The need to pay GPT in a single instalment causes great di�culty amonglow-income taxpayers and payment in several instalments is not practical, given thecosts of collection. These timing problems do not occur with, for example, sales taxes.

A basic problem is that of poverty and lack of cash income. One o�cial statedinterestingly that `people who are unemployed give this as an excuse for not payingtaxes. They do not even fear imprisonment'.

Collection poses particularly great problems due to large numbers of payers allpaying small amounts and the nature of this direct tax system which requires person-to-person contact in order to e�ect payment. This itself invites confrontation: asstated by another o�cial, `taxpayers need to be harassed before they will pay, makingit very expensive for the local council which has to run after the defaulters'.

Problems of taxpayer resistance

A widely observed phenomenon in Uganda is unwillingness to pay on the part oftaxpayers associated with a perceived failure by local authorities to deliver thecorresponding level or quality of services. More speci®cally, the feeling is that thefunds collected are used largely to cover the wages and allowances of the tax collectoror of civil servants at district headquarters rather than being applied to tangibleprojects likely to bene®t the payer. The inadequate level of Central Governmentfunding means this feeling is often quite justi®ed.

This resistance is frequently increased at the local or national level by politicalleaders seeking to advance their popularity generally or in advance of elections,including District Council members, who in particular should be encouraging thepublic to pay. Council elections held in Uganda in 1998 resulted in large falls inrevenue collection right across all districts and urban authorities.

9Observation made by an o�cial from Iganga District.



Problems of administrative capacity and probity

The distances involved and the lack of transport available to enumeration teamsare a fundamental problem, as already indicated. Apart from encouraging `desk'assessments, these create problems for district administrations of control andsupervision of revenue collection in the sub-counties. Lack of education among chiefsand lack of training in enumeration and assessment are a further handicap, someof them having di�culty in understanding or applying the guidelines laid downand rendering them more inclined to use rough-and-ready judgemental methods.This situation is aggravated by the lack of an adequate number of veterinary andagricultural sta� at lower levels. The cadres used for the registration of assets at thehousehold level frequently lack the required level of technical know-how and services.

Transporting the cash collected from sub-county stations to a bank presentsmajor problems, particularly since the Uganda Commercial Bank's rural extensionprogramme was wound up in 1996, and, of course, in the more remote rural areas,sub-county cashiers face the danger of being robbed of the collected funds on the wayto the nearest main town. The large number of separate small amounts collected alsomeans that cashiers often fail to bank collected funds daily, accumulating funds andincreasing the likelihood of misappropriation. Problems of fraud exist also in theprinting, serving and distribution of tax certi®cates. Taxpayers are sometimes givenfalse acknowledgement chits instead of actual tax certi®cates, whether by clerks orchiefs, and their tax contributions diverted.

ALTERNATIVE DIRECTIONS

One reason why District authorities rely on graduated tax is that most of the èasy'taxes, taxes on commodities, have been pre-empted by Central Government, althoughthey fall on local activities and consumers in the districts. The extent to which localrural economies are already being taxed, through di�erent indirect taxes onexpenditure levied by the Central Government, not accruing to district authorities,is not always realized. In Uganda in 1995±1996, taxes on goods and servicesaccounted for over 80 per cent of Central Government revenue. The di�culty for localgovernments seeking their own revenue is that these taxes are most convenientlycollected centrally; and, as Bahl (1996, p. 2) points out, given Uganda's exceptionallylow tax e�ort, at less than 10 per cent of GDP, òne of the lowest rates of revenuemobilisation in the world', local governments will ®nd it di�cult to persuade CentralGovernment to allow them to adopt revenue enhancement programmes whichcompete with Central Government for the same revenue base. He suggests that `theright strategy' is for local governments to be allocated revenue sources where theyhave a comparative advantage in tax administration. However, the main sourceallocated to local governments in Uganda's case, GPT, while certainly requiring localadministration, is, as demonstrated above, full of administrative problems.

The only obvious alternatives in the districts, other than those already tapped byCentral Government are taxes on land or agriculture. The focus of the present paperis on the operation of GPT rather than possible alternatives, but we may neverthelesscomment brie¯y on these.



Agricultural incomes in Uganda are exempt from income tax (except at the bottomend only, via GPT) and there are no taxes on land, despite the fact that Uganda isprimarily an agricultural country and has a relatively rich agricultural sector. A factorhere is that both local and national politicians and civil servants own land, eithermedium-sized holdings or even large commercial farms and ranches. There is a morewidespread national and possibly cultural hostility to the concept of paying tax onland and even residential property in Uganda, but this hostility may be exaggeratedand might be countered by appropriate sensitization. An immediate possibility is alocal tax on larger commercial farms (as opposed to smallholdings) and ranches. Thiswould not substitute for the still more desirable objective of bringing incomes fromthese commercial enterprises within the ambit of income tax. However, despite thepolitical obstacle mentioned, there is considerable current support in Uganda for sucha move, which can be justi®ed also in terms of proportionate public services, part-icularly road access, enjoyed by the enterprises. The change can be handled quitesimply under existing property tax legislation.

In a number of districts this would make a useful contribution to local governmentrevenues. However, taxing only large farms would not solve the problem, since inUganda the bulk of land is cultivated by smallholders. This sector does not lacktaxable capacity, however, as the smallholder sector is highly strati®ed, with widevariation in size of landholding. With this in mind, the ODAReport on policy optionsfor enhancing district revenue suggested the introduction of a `Rural DevelopmentCharge' (RDC) based on acreage (ODA, 1996, pp. 60±83). With a proportional taxapplied to the number of acres but excluding the ®rst acre, it was calculated, based onthe 1991 Agricultural Census for Uganda, that it would be possible to exempt in thisway half the farm population currently paying GPT, as well as to fully replace the taxwith an RDC of just Shs 1200 (US$1.2) and to double revenue with a charge ofShs 2500. The present lowest band for GPT in any district in Shs 2000.

A possible drawback would be collection costs. These can be high with re®ned landtax systems requiring full cadastral surveys, precise demarcation of holdings and landtitles, none of which are generally available in Uganda. The proposal here is for arough-and-ready assessment of the number of arable and grazable acres owned,assessed locally by the sub-county chief and council. The tax rates to be applied peracre would also be determined locally according to land productivity in the sub-county. Assessment on this basisÐnot as the equivalent of a wealth tax but for a muchmore modest contribution to local, not central, government revenuesÐshould bequite simple compared with the complex data requirements of GPT and require onlyminimal year-to-year changes, and thus would entail quite low collection costs,dispensing with the current àrmy' of sub-county assessors. It should be possible tomirror the strati®cation of landholdings in the strati®cation of tax contributions,avoiding the concentration around a few tax bands exhibited by GPT, producing, withthe exemptions referred to, both more equity and reduced social costs of collection.

An obvious second potential limitation is that the RDC would not extend to non-farm incomes, in either rural or, especially, urban areas outside the formal sector.GPT, as conceived and later developed, as we have seen, was as a direct tax on allforms of income, including those from wage and self-employment in non-agriculturalactivities. Informal sector wages, both rural and urban, are extremely low in Ugandaand can sensibly be exempted, given also the indirect taxation of such incomeswhich already exists. Informal sector enterprise incomes, including incomes from



self-employment, can be approached by stratifying more sharply in line with deemedincome levels in each activity, the existing system of licences and fees, much as is donealready in applying GPT to the same activities.

What neither GPT nor central income tax captures in an economy such as Uganda,without a large formal sector, are the widespread and often very substantial incomesearned in domestic and export±import trade and in services, much or most of whichare generated outside the formal sector and evade income tax. The scale of suchearnings is re¯ected currently in Uganda in the growth of expensively built suburbanresidences in Kampala and elsewhere. GPT has almost certainly been even lesse�ective in coverage of such incomes (as suggested by the GPT data for Kampalaabove) than in relation to smallholder incomes. Licences and fees, even as adjustedabove, would only cover the bottom portion of such incomes. The more substantialincomes can only be reached indirectly through property tax.

The potential for property tax in Kampala, in particular, is enormous. It is possibleto identify a Greater Kampala economy, distinct from the remainder of Uganda andfrom other urban centres. Bahl (1996, p. 3) estimates Kampala City already toaccount for more than a quarter of total locally raised revenues, despite its weak taxe�ort. As he points out, if Kampala and other urban areas were made more ®scallyself-su�cient, Central Government grant funds could be freed up for other uses, inparticular to assist the revenue-poor rural districts.

The collection of property tax in Uganda is in a state of disrepair, followingyears of political disturbance and administrative neglect, and has been slow to recoverowing to the retention of old-fashioned and cumbersome valuation methods. Massvaluation methods could be introduced which would generate the revenue due withcomparatively low collection costs, certainly in comparison with GPT.

One advantage which GPT does have, in principle, is that it involves the bulk ofcitizens in the government process, disseminating the notion that all should con-tribute something, however small, to the provision of public services and to develop-ment. This can be partly achieved, in a di�erent way, by extending fees and chargesfor services rendered, already widely operative, at some social cost it should be said, inhealth and education, and by the combination of taxes suggested above. Fullparticipation in the payment of direct taxes can probably not be achieved at thepresent very low level of per capita incomes in Uganda, without compensating dis-advantages in terms of equity.

REFERENCES

Bahl, R. (1996). Uganda: Fiscal Decentralisation and Intergovernmental Finance, Paperprepared for the World Bank, Policy Research Center, Georgia State University.

Cheema, G. S. and Rondinelli, D. A. (eds) (1983). Decentralisation and Development: PolicyImplementation in Developing Countries, Sage, Beverley Hills.

Cohen, Sir A. (1954). In Uganda Today and Tomorrow, a Review of Achievement and Promise,East African and Rhodesia, London, writing as Àtlas'.

Davey, K. (1974). Taxing a Peasant Society, the Example of Graduated Taxes in East Africa,Charles Knight, London.

DFID (1997). Strategies for Local Government Revenue Enhancement in Uganda, Workshop onPolicy, Administration and Implementation, Department for International Development/Crown Agents, Sutton.



Livingstone, I. (1997). `Tax policyÐthe issues to be considered', in DFID, 1997.Mahler, W. (1997). Uganda: Issues in Decentralisation, Fiscal A�airs Department, IMF.Muwanga-Zake, E. S. K. (1983). Imputation Values for 1984 Graduated Tax Assessment,Report to the Ministry of Local Government.

Nelson, E. (1994). Tax Policy and Administration Working Group: Progress and Constraints toProgress, Uganda National Forum.

ODA (1996). Uganda: Enhancing District Revenue Generation and Administration, FinalReport, Crown Agents, Sutton.

Parker, A. (1995). Decentralisation: The Way Forward for Rural Development?, World BankPolicy Research Working Paper 1475.

Republic of Uganda (1987). Report of the Commission of Inquiry into the Local GovernmentSystem.

Republic of Uganda (1994). Iganga Tax Riots Commission of Inquiry Report, Ministry of LocalGovernment, Kampala.

World Bank (1995). The Challenge of Growth and Poverty Reduction, Report 14313-UG,Country Operations Division, Uganda.



Documents

Raising local authority district revenues through direct taxation in a low-income developing country: evaluating Uganda's GPT