KRA

Tax Appeals Tribunal: Key Rulings That Businesses Should Know About

The Tax Appeals Tribunal is Kenya’s principal forum for resolving tax disputes, and its decisions form an increasingly important body of precedent. Several rulings from late 2025 and early 2026 carry direct practical lessons for businesses, whether on transfer pricing methodology, the procedural standards KRA assessments must meet, or the deductibility of core financial costs. […]
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KRA Publishes Draft APA Regulations: A Framework Taking Shape

On 3 November 2025, the Kenya Revenue Authority published the Draft Income Tax (Advance Pricing Agreement) Regulations 2025, inviting comment from taxpayers and professionals before finalisation. The draft regulations set out a structured administrative process for the APA framework introduced under Section 18G of the Income Tax Act by the Finance Act 2025, which took […]
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Can KRA Challenge Your Old Tax Losses? The Patel Case and the 5-year Limit

Vijay Kumar Shamji Patel v Commissioner For Legal Services & Board Co-Ordination Services. The Tax Appeals Tribunal’s decision in Patel v KRA confirms that KRA is barred from amending tax assessments after five years unless fraud or willful neglect is proven. The case reinforces important taxpayer protections against prolonged audits and retrospective reassessment of historic […]
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When Does a Marketing Subsidiary Become a Permanent Establishment?

Travelport Services (Kenya) Limited v Commissioner of Legal Services Board Coordination In February 2026, the Tax Appeals Tribunal issued a landmark ruling in a case centered on whether a Kenyan subsidiary of a global travel technology group constituted a Permanent Establishment of its UK parent, and what that meant for additional assessments spanning corporate tax, […]
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The Return of Nil Filings: Navigating the New Compliance Landscape Strategic guidance on the KRA’s reinstated yet intensified verification protocols.

KRA has reinstated nil returns filing on iTax following a temporary suspension. The suspension was a calculated system upgrade designed to transition the tax environment into an era of automated data verification. Key Takeaway: The ‘Nil Return’ option is no longer an automatic right; it is now a conditional privilege granted only after passing a […]
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Bank Statements

Are your Bank Statements and Tax Returns coherent?

 Rebecca Fashion (Kenya) Limited v Commissioner Investigations & Enforcement Tax Appeal E1331 Of 2024 | [2025] KETAT 278 (KLR)  Background Rebecca Fashion (Kenya) Limited faced additional tax assessments totaling Kshs 106,300,709 following investigations by KRA covering the tax period 2018–2022. KRA spotted variances and inconsistencies between what Rebecca Fashion declared in tax returns and what […]
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