Transfer Pricing Archives - Intelpoint Consulting

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 […]

Transfer Pricing in Kenya: A New Era of Certainty

For years, transfer pricing disputes in Kenya followed a familiar pattern. The KRA raises an assessment. The taxpayer objects. The matter moves to the Tax Appeals Tribunal. Years pass, costs accumulate, and the outcome stays uncertain. A landmark change introduced through the Finance Act 2025 is set to break that cycle: Kenya now has a […]

THE RISING TIDE OF TRANSFER PRICING AUDITS IN AFRICA: A STRATEGIC GUIDE FOR MULTINATIONALS

Across the African continent, tax authorities are significantly strengthening their enforcement of transfer pricing rules as part of broader efforts to protect domestic tax bases and reduce revenue leakage. Transfer pricing has increasingly become a central focus of tax audits across many African jurisdictions. Revenue authorities in countries such as Kenya, Nigeria, South Africa, Tanzania, and […]

Permanent Establishment: The Hidden Double Taxation Risk in a Remote World

You don’t need to own an office to have a tax problem. A software company allows a senior engineer to work from a home office in a neighboring country for six months. A manufacturer sends a team to a client’s site to oversee a long-term project. A sales director travels frequently to negotiate deals, but […]

Intra-Group Loans & Transfer Pricing in Kenya

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 […]

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 […]

TRANSFER PRICING IN THE UAE: SEPTEMBER DEADLINE – ARE YOU READY?

By September 30, 2025, UAE businesses within the scope of corporate tax must have their FY 2024 audited financial statements finalized, transfer pricing (TP) adjustments completed, and related-party disclosures submitted. This marks one of the most significant compliance milestones since the introduction of corporate tax in the UAE. With the first real deadlines now imminent, […]