Transfer pricing - Kenya

HexaTP was founded by a group of six enthusiastic, diligent professionals from varied domains i.e. finance, economics, legal, science and technology. Despite having varied domain expertise, all our professionals have individually spent a significant part of their career specifically in Transfer Pricing.

These professionals have either worked with Revenue Department or with BIG 4s or in industry and have earned valuable experiences over many years. They have a holistic view across all areas of transfer pricing such as Legislation, Implementation, Planning, Documentation, Negotiation, Litigation, among others.

Cumulatively having more than 100 years of experience in cross border taxation, we are capable in assisting and responding to all transfer pricing related queries and solutions.

Three Cs of Transfer Pricing, Comprehensiveness, Contemporaneous Data, Compliance can be best worked only with mix of efficient use of technology and domain expertise. These have led to the creation of HexaTP.

We are a pioneer B2B Transfer Pricing Solutions provider

Transfer Pricing Documentation Solutions

When, while the lovely valley teem with vapour around me, and the meridian.

Transfer Pricing Documentation Solutions

When, while the lovely valley teem with vapour around me, and the meridian.

Transfer Pricing Documentation Solutions

When, while the lovely valley teem with vapour around me, and the meridian.

Transfer Pricing Documentation Solutions

When, while the lovely valley teem with vapour around me, and the meridian.

Transfer Pricing Regulations

Get authentic and reliable analysis curated by expert TP professionals having combined experience of 100+ years HexaTP provide bespoke and comprehensive benchmarking solutions. Team HexaTP having cumulative experience of 100 + years extensively in Transfer Pricing understands the relevance of comprehensive and in-depth benchmarking analysis for determination of arm’s length margin.
  • Section 18(3) of the Income Tax Act CAP 470 provides that, ‘Where a non-resident person carries on business with a related resident person or through its permanent establishment and the course of that business is so arranged such that it produces to the resident person or through its permanent establishment either no profits or less than the ordinary profits which might be expected to accrue from that business if there had been no such relationship, then the gains or profits of that resident person or through its permanent establishment from that business shall be deemed to be the amount that might have been expected to accrue if the course of that business had been conducted by independent persons dealing at arm’s length’.
  • In addition to the above, a multi-national enterprise (MNE) is required to comply with The Income Tax (Transfer Pricing) Rules, 2006 which offer guidelines on how to apply the arm’s
  • The rules prescribe a general overview on the application of transfer pricing rules and Kenya heavily relies on the OECD guidelines which offer a more formulaic expression on implementation.
  • The TP rules empower the Commissioner of Domestic Taxes (KRA) to request for TP documentation to any Multinational enterprise operating in Kenya on transactions where transfer pricing is applicable.
  • Section 18(3) of the Income Tax Act CAP 470 provides that, ‘Where a non-resident person carries on business with a related resident person or through its permanent establishment and the course of that business is so arranged such that it produces to the resident person or through its permanent establishment either no profits or less than the ordinary profits which might be expected to accrue from that business if there had been no such relationship, then the gains or profits of that resident person or through its permanent establishment from that business shall be deemed to be the amount that might have been expected to accrue if the course of that business had been conducted by independent persons dealing at arm’s length’.
  • In addition to the above, a multi-national enterprise (MNE) is required to comply with The Income Tax (Transfer Pricing) Rules, 2006 which offer guidelines on how to apply the arm’s
  • The rules prescribe a general overview on the application of transfer pricing rules and Kenya heavily relies on the OECD guidelines which offer a more formulaic expression on implementation.
  • The TP rules empower the Commissioner of Domestic Taxes (KRA) to request for TP documentation to any Multinational enterprise operating in Kenya on transactions where transfer pricing is applicable.
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    For further information on transfer pricing in Kenya please contact:

    Mohammad Taher Shaikh [FCA, LL.B.]

    Leader – Gulf Practice
    20+ years, experience in International Tax and Transfer Pricing space. Worked with A.F. Fergusson, KPMG, Ernst & Young and Deloitte wherein he served numerous Fortune 500 clients in different business space like consumer goods, automotive, IT and ITES. He did his masters in Law with Mumbai University and was part of the Tax Controversy Management Team at Deloitte.
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