Kenya introduced transfer pricing rules in 2006 to supplement the provisions of section 18(3) of the Income Tax Act (ITA) 2006, Chapter 470, as amended by Income Tax Rule, 2012 and Income Tax Rule, 2014. The arm’s length principle is laid down in these rules.
Section 18(3) of the ITA states that transactions between a non-resident person and a related resident person should be at arm’s length.
The Kenya Revenue Authority (‘KRA’) has proposed to introduce detailed transfer pricing practice notes. To date, they have not yet been published.
In addition to the rules laid down in section 18(3) of the ITA, the KRA applies the 2017 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Guidelines) and the UN Transfer Pricing Manual (UN TP Manual).
HexaTP Provides robust transfer pricing documentation services as per the guidelines prescribed by OECD and UN TP Manual
HexaTP delivers and deals with peculiar intra-group transactions inter alia intra group financing. intangibles, intra-group services, efficiently.
We help design and implement Global TP Policy / review Agreements for Multinational Corporations. We also provide TP litigation support services.
We have access to various public financial and company databases, industry and directories which assist us to render comprehensive TP analysis.
Principal - Kenya Practice
Cookie | Duration | Description |
---|---|---|
cookielawinfo-checbox-analytics | 11 months | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics". |
cookielawinfo-checbox-functional | 11 months | The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional". |
cookielawinfo-checbox-others | 11 months | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other. |
cookielawinfo-checkbox-necessary | 11 months | This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary". |
cookielawinfo-checkbox-performance | 11 months | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance". |
viewed_cookie_policy | 11 months | The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data. |