Lecture 32 Β· Naivas was run from Nairobi behind a Mauritian company, and a KSh5.2 billion sale was taxed in Kenya.
π»ππ πͺπππ πΉπππ: A Mauritian holding company sold a stake in Naivas for KSh5.2 billion, but the real decisions were made in Kenya. The tribunal held the company was a Kenyan tax resident and taxed the gain, then made a Kenyan arm pay it.
Illustration: Precursor
A family holds its Kenyan business through a company registered abroad, with local nominee directors and a mailbox address. The real decisions are made in Kenya. When the structure sells a stake, the tax authority asks where the company truly lives.
Put yourself in the group's chair. Does registration abroad decide residence, or does something else?
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Lecture 33 Β· London Distillers was assessed on missing bottles, and the method held at KSh3 billion.
π»ππ πͺπππ πΉπππ: KRA built a KSh3 billion assessment from gaps between stamps bought, bottles bought and money banked. A tribunal threw it out on a theory nobody had pleaded; the High Court restored it and held the method sound.
Tax and financial judgement Β· 4 min read Β· Paid