Unilever Sri Lanka Limited vs Commissioner General of Inland Revenue – CA TAX/0018/2014-2022

In the case between Unilever Sri Lanka Limited (Appellant) and the Commissioner General of Inland Revenue, Department of Inland Revenue (Respondent), the court addressed whether the determination of the Tax Appeals Commission (TAC) was time barred under statutory time limits and whether the Appellant should be deemed the “manufacturer” for VAT purposes in relation to trademarked household products. The court held that the Appellant’s extensive direction and control over contract manufacturers met the statutory definition of “manufacturer” under section 83 of the VAT Act, thereby upholding the tax liability on the Appellant. The principle reaffirmed is that effective control, supervision, and the contractual framework can render an entity the manufacturer for tax purposes. The decision reli