Tax Appeals Tribunal Archives - Intelpoint Consulting

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. […]

A KES 6.7 Billion Reality Check: Does Your Transfer Pricing Match Your Economic Substance?

In January 2026, Kenya’s Tax Appeals Tribunal delivered a monumental decision in the dispute between Del Monte Kenya Limited and Kenya Revenue Authority. The ruling offers valuable insight into how tax authorities approach transfer pricing enforcement and what multinational groups must do to remain compliant and defensible. Background KRA audited Del Monte Kenya’s transfer pricing […]

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 […]

Landmark VAT Ruling in Kenya: Tribunal Confirms PSP Services Are VAT-Exempt

Kenswitch Limited v. Commissioner of Domestic Taxes Tax Appeal No. E1336 of 2024 Background The Tax Appeals Tribunal has delivered a landmark decision in favour of Kenswitch Limited, a licensed Payment Service Provider (PSP), holding that PSP commission income qualifies as VAT-exempt financial services under Paragraph 1(b) and 1(m) of the First Schedule to the […]

When Does the Burden of Proof Shift From Taxpayer to KRA?

Commissioner of Investigations and Enforcement v Traneshvi Limited Income Tax Appeal E142 of 2023 (2025) Background Traneshvi Limited operates a real estate business generating rental income through 11-month renewable tenancy agreements. 2018: KRA conducted an audit covering tax years 2015-2017 which reconciled with the company’s declared rental income and verified claimed expenses. No issues were […]