30/09/2026
A recent Tax Appeals Tribunal decision in Equator Bottlers Ltd v. Commissioner of Domestic Taxes (TAT Appeal No. E158 of 2026), provides an important clarification on excise duty relief.
The Tribunal held that plastic bottle preforms used in the manufacture of bottles qualify as raw materials under Section 14(1) of the Excise Duty Act. As a result, the excise duty paid on the preforms could be offset against the excise duty payable on the finished beverages.
Tax impact
• Prevents hidden double taxation on essential manufacturing inputs.
• Preserves cash flow by allowing eligible excise duty offsets.
• Provides greater certainty for manufacturers with integrated production processes.
• Reinforces that established court precedent can be relied on when challenging similar tax assessments.
For manufacturers, this ruling clarifies that where packaging is an essential part of the excisable product, the components used to create that packaging may qualify for excise duty relief.