COMMISSIONER GENERAL TANZANIA REVENUE AUTHORITY VS COCA COLA KWANZA LIMITED 2025 TZCA 103 (26 FEBRUARY 2025)

Abstract

The respondent, Coca-Cola Kwanza Limited (CCKL), a Tanzanian subsidiary of Coca-Cola Beverages Africa, imported refined white industrial sugar under the duty remission scheme between July, 2014 and June, 2017. In 2017, the appellant, the Commissioner General Tanzania Revenue Authority (TRA), conducted a verification exercise, alleging that CCKL had failed to account for 5,067 metric tons of sugar. As a result, a demand note for unpaid duties amounting to TZS 7,310,524,825.45 was issued. Although CCKL provided reconciliations from its Systems, Applications, and Products in Data Processing (SAP) accounting system, showing that the disputed sugar was in transit, stored, or used in subsequent financial periods, the appellant rejected the reconciliation, contending that the duty remission period required importation and sugar usage within twelve (12) months.