Tax and Legal Alerts

We provide a wealth of publications by PwC Kenya providing informed commentary on current developments in the tax and legal arena.

Through analysis and comment on new law and judicial decisions of interest, they assist business executives to identify developments and trends in law and revenue practice that might impact their business.

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In this alert:

Kenya gazettes new Transfer Pricing Rules, 2026

Kenya has gazetted the Income Tax (Transfer Pricing) Rules, 2026 under Legal Notice No. 186 of 2026. They replace the 2006 Rules. The traditional transfer pricing methods and the "most appropriate method" approach remain unchanged, but there are important developments, including:

• a new commodity pricing rule that uses quoted prices averaged over 15 days before and 15 days after shipment
• coverage of more types of transactions, including financing, insurance, business restructurings, cost distribution arrangements and derivatives
• more detailed documentation requirements, including counterparty financial statements and segmented data that a Kenyan entity may not always have

The Rules raise compliance expectations and strengthen KRA's position in transfer pricing audits. They still leave key questions unanswered, such as how benchmarking should work and what level of documentation KRA will consider sufficient. Taxpayers should review their related-party arrangements, intercompany agreements and transfer pricing documentation in light of these updates.