Kenya’s tax landscape is changing fast, and intra-group financing is right at the center of it. KRA has steadily intensified its scrutiny of cross-border intercompany transactions, and intra-group loans sit at the top of its audit priority list. For MNEs operating in Kenya whether as regional treasury hubs, subsidiaries receiving funding from offshore parents or […]
KRA recently via a public notice that provided deemed interest rate to be used for the last quarter of 2025 (October-December) set at 8%. Deemed interest applies when related-party loans or intercompany balances carry zero or below-market interest rates, triggering tax adjustments and withholding tax. KRA treats interest-free or long-overdue intercompany receivables as financing arrangements […]


