Tax
Strategic tax counsel for complex transactions, KRA audits, transfer pricing and Tax Appeals Tribunal litigation.
How we work this practice.
We help corporates, multinationals and high-net-worth individuals plan, structure and defend tax positions across Kenya. Our work covers transfer pricing, indirect tax, withholding and excise, cross-border treaty positions, and the full lifecycle of KRA engagement from audit through objection, Tribunal and appeal.
Tax in Kenya has shifted from compliance exercise to commercial battleground. The KRA is more assertive, the Tax Appeals Tribunal more demanding on evidence, and the policy landscape moves on every Finance Act. Our role is to give clients positions that are commercially viable, technically defensible and ready for the scrutiny they will attract.
We combine transactional tax structuring with seasoned tribunal advocacy. The same partners who design the holding-company architecture stand up in the Tribunal when the KRA challenges it years later, so advice is never theoretical and litigation is never disconnected from the deal.
- KRA audits expanding into related-party and digital-services positions
- Tribunal congestion and shifting evidentiary standards
- VAT refund recovery and excise classification disputes
- Personal tax exposure for cross-border executives
What we deliver.
A deliberate four-step approach.
Strategic counsel, executed with the discipline of a top-tier institution.
Position review and risk assessment
Strategy memo and opinion
KRA engagement or tribunal filing
Resolution, settlement or judgment
Distinctions that matter to the outcome.
Senior counsel with Tax Appeals Tribunal trial experience
Combined commercial-and-tax view, not siloed advice
Disciplined KRA engagement protocols across audit, objection and appeal
Chartered tax-adviser depth on transfer pricing
Where we apply this practice.
Who you'll work with.
Gertrude Kibare
Managing Partner. Leads the firm's litigation and banking & finance practice with a focus on strategic, resilient counsel.
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Margaret L. Kishoiyian
Partner. Combines a Master of Laws in Indigenous Peoples Law & Policy with strong commercial and advisory experience.
SEE FULL PROFILEAnswers from our desk.
Do you handle KRA objection filings?+
Yes, including notice of objection, statement of facts and supporting bundles.
Can you act in the Tax Appeals Tribunal and on appeal?+
Yes. We appear in the Tribunal as lead counsel and pursue further appeals through the High Court and Court of Appeal where the matter justifies it.
How do you approach transfer pricing documentation?+
We build TP policies that are commercially honest, OECD-aligned and KRA-defensible, with master file, local file and benchmarking refreshed on a schedule rather than under audit pressure.
Do you advise on Double Taxation Agreement positions?+
Yes, including treaty residence, beneficial ownership, withholding rates and the increasingly contested principal-purpose test.
Can you handle VAT refund claims and excise disputes?+
Yes, from initial filing and audit defence through to Tribunal litigation where the KRA delays or denies refunds without legal basis.
Articles, publications and legal updates.
Tax Appeals Tribunal: Three Trends Reshaping KRA Disputes
From transfer pricing to digital service tax, the structural shifts in how the Tribunal is approaching revenue disputes.
East African M&A: Where Capital Is Moving in Q1 2026
Sector flows, deal structures and the regulatory choke-points shaping mid-market M&A in East Africa.
Discuss your matter, confidentially.
Whether you require a confidential consultation or a free case evaluation, our partners are ready to listen.