Tax Consulting Solutions

Fast-moving changes and significant regulatory developments


Multinational businesses are increasingly affected by tax, legislative and regulatory developments throughout the world. Understanding the impact of these developments on business operations and transactions between countries is vital for a company’s success.

PwC consults on general matters related to interpretation and application of Kenyan tax legislation, local and international tax structuring, tax advice on inbound and outbound investment, structuring EPC contracts, consulting on corporate income tax, VAT, royalties and other matters.

PwC international structuring group is experienced in addressing these developments as well as all aspects of international taxation. Our teams are able to help you structure your business in a tax-efficient manner, both locally and globally.


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How we can help

Transfer pricing

PwC Kenya transfer pricing (TP) team is a regional transfer pricing center of excellence serving the East Africa market including Kenya, Uganda, Tanzania, Rwanda and Zambia. The center of excellence is linked to the PwC Global TP network which ensures that the center is up to date on global developments and all work products are in line with the PwC Global network’s quality standards.

We can work with you to:

  • Review existing transfer pricing (TP) documentation and policies to identify risks and ways in which the policies can be tax optimized.
  • Prepare Kenyan transfer pricing documentation in line with the Kenya tax and transfer pricing regulations including Country by Country Reporting.
  • Assist in securing advanced pricing agreements with the revenue authorities.
  • Assist you to formulate your transfer pricing policy to ensure that it is compliant with the arm’s length principle.
  • Review intercompany agreements to mitigate TP risks and ensure that they are aligned to TP documentation.
  • Help you effectively manage and assist to resolve revenue authority disputes and transfer pricing adjustments.
  • Provide in-house training on transfer pricing implementation and emerging transfer pricing issues to finance and tax staff.

International tax services

When global opportunity means global complexity, you need strategic, integrated international tax solutions.

PwC international tax team provides cross border tax reviews and reorganizations and value chain transformation services with a full view of the total tax costs and impact on profit repatriation.

Our services include:

  • Advice on holding company locations with economic substance in mind.
  • Funding considerations such as debt, equity, redeemable preference share capital and mixed financing.
  • Interpretation of double tax treaties and how to utilize the treaties.
  • Permanent establishment risk and the tax issues to be considered.
  • Residency risk and tax issues to be considered.
  • Profit repatriation considerations and exit considerations.
  • Interaction of transfer pricing with international tax issues – shared services, franchise fee, limited risk distributors.
  • Taxation of dividends, interest, management or professional fees and royalties.

Mergers and acquisitions

Whatever type of transaction you are contemplating - an acquisition, merger, joint venture, disposal, restructuring, financing and refinancing, your tax obligations must be carefully assessed and your cash flows optimised.

We provide the services below:

  • Structuring of investments (inbound and outbound) from a tax perspective.
  • Review of the financial model in respect of the proposed acquisition/merger/ investment from a tax perspective to confirm the accuracy of tax assumptions.
  • Carry out pre-acquisition or pre-sale tax due diligence.
  • Resolve complex tax issues that are assumed during a share deal.
  • Assess and manage acquisition / merger risk from a tax perspective.
  • Structure acquisitions/mergers to optimise net cash flows.
  • Ensure that tax compliance requirements are met throughout the deal.
  • Integrate a newly acquired business with existing operations.
  • Provide post deal/acquisition tax support services to ensure that acquired entity becomes tax compliant.
  • Assess the tax risks where a significant debt is involved.
  • Contemplate an eventual exit.
  • Corporate simplification and internal reorganization.

  • Tax support during liquidation of an entity.


Tax controversy and dispute resolution

A convergence of economic and legislative forces has resulted in a substantial increase in the number and size of tax audits, assessments, and disputes with the revenue authority. Virtually no area of tax enforcement has escaped this phenomenon.

Explore more on our Tax Controversy and Dispute Resolution page here.

Tax policy and administration

Our role in tax policy involves working with a wide range of stakeholders and influencing the tax regime. Our tax professionals focused on tax policy provide the following services:

  • Working with the Government in influencing the development of an efficient tax regime and supporting administrative systems.
  • Building trust through influencing key Stakeholders and therefore support Clients in managing their relationships with these stakeholders.
  • We assist our clients strengthen trust and transparency with their stakeholders by carrying out total tax contribution studies. We can help you to identify, extract, analyse and report the taxes you pay.
  • Assisting our clients in carrying out tax policy gap analysis studies.
  • Assisting our clients in the application for a private ruling to the Commissioner (Kenya Revenue Authority) for interpretation of a tax law in relation to a transaction entered to by our clients.
  • Lobby for change in the tax law through the National Treasury, National Assembly, Kenya Revenue Authority and other stakeholders.


Corporate tax services

Tax can unlock opportunities and add significant value for the business. Our approach is founded upon our understanding of the business circumstances of our clients. We tailor our services around the client needs and not the other way around.

We provide:

  • Tax advice and interpretation of tax legislations.
  • Review of contracts from a tax perspective and advising clients on the implications of tax clauses.
  • Sensitising clients on change in tax legislation/impact of new legislation.
  • Applications for income tax exemptions and renewals.
  • Advice on the tax treatment of matters such as Real Estate Investment Trusts, Limited Liability Partnerships, Capital Gains Tax, digital service tax, financial derivatives amongst others.
  • Tax trainings aimed at equipping employees with the necessary tax knowledge for efficient conduct of the business.
  • Tax health checks and capital expenditure review to determine the areas of tax risks and opportunities.
  • Regional tax desk for your investment in Horn of Africa.


People and organisation

People Risk Assurance (“PRA”) is part of a multi-disciplinary offering within the Tax Consulting Solutions business unit and works alongside other PwC tax and legal specialty teams both locally and internationally to deliver unrivalled employment tax consulting solutions to organisations.

In doing so, we help companies with the planning and implementation of their strategy through practical advice which ensures that such organisations pay the right employee taxes and social security for both their local and expatriate employees.

Explore more about our People and organisation tax services here.


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Contact us

Simeon Cheruiyot

Simeon Cheruiyot

Partner, Tax Consulting Services Leader, PwC Kenya

Tel: +254 (0724) 256655

Titus Mukora

Titus Mukora

Partner/Director, PwC Kenya

Tel: +254 (20) 285 5000

Alice Muriithi

Alice Muriithi

Partner | Tax and Legal Services, PwC Kenya

Tel: +254 20 2855000

Sunny  Vikram

Sunny Vikram

Partner | Tax and Private Business Service, PwC Kenya

Tel: +254 (0) 748 599 580