Policy Note · Telling capital from income
What a receipt or a loss is, capital or revenue, decides whether it is taxed or deductible.
Tax and financial judgement · 10 Nov 2026 · 1 min read · Paid
Analysis
Stories that begin with something visible and ask what larger system is quietly being revealed.
Policy Note · The records the law requires, and for how long
Keep the documents behind every figure for five years, in a form you can produce.
Tax and financial judgement · 10 Nov 2026 · 1 min read · Paid
Policy Note · Pricing related-party dealings
A transaction with a connected company must stand at the price unconnected parties would have agreed.
Tax and financial judgement · 10 Nov 2026 · 1 min read · Paid
Policy Note · When withholding tax falls due on a book entry
Interest and fees to a related party are paid for withholding tax when credited in your books, not when the money moves.
Tax and financial judgement · 10 Nov 2026 · 1 min read · Paid
Policy Note · Where your company is really taxed
A company is resident where its real management and control sit, whatever its certificate of incorporation says.
Tax and financial judgement · 10 Nov 2026 · 1 min read · Paid
Policy Note · Lodging an objection so it counts
An objection must be supported, in time, and provably received, or it is no objection at all.
Tax and financial judgement · 10 Nov 2026 · 1 min read · Paid
Policy Note · Who has to prove what in a tax dispute
The taxpayer must prove an assessment wrong; once it does, the authority must answer with specifics.
Tax and financial judgement · 10 Nov 2026 · 1 min read · Paid
Policy Note · How far back the Commissioner can go
An assessment may be amended within five years of your return; reaching further needs proof of fraud or neglect.
Tax and financial judgement · 10 Nov 2026 · 1 min read · Paid
Policy Note · Best-judgment assessments and the records that defeat them
Where your records are missing the Commissioner may estimate your tax; where they are complete it may not.
Tax and financial judgement · 10 Nov 2026 · 1 min read · Paid
Policy Note · The 60-day objection clock
When the Commissioner lets a valid objection sit for 60 days, the law may decide it for you.
Tax and financial judgement · 10 Nov 2026 · 1 min read · Paid
Lecture 62 · Wadi Degla saved its PAYE with petty-cash vouchers, then paid withholding tax on interest it never sent.
𝑻𝒉𝒆 𝑪𝒂𝒔𝒆 𝑹𝒐𝒐𝒎: A Nairobi sports club beat most of a KSh 58 million demand by documenting its director's drawings, but lost on withholding tax, because interest merely credited in the books is paid for tax even when no money moves.
Tax and financial judgement · 9 Nov 2026 · 5 min read · Paid
Lecture 61 · Mwanzi issued bonus shares from its own reserves and refused to call it a dividend.
𝑻𝒉𝒆 𝑪𝒂𝒔𝒆 𝑹𝒐𝒐𝒎: KRA treated Mwanzi's bonus shares, issued out of retained earnings, as a deemed dividend and billed KSh 70 million. The tribunal held that a bonus issue moves nothing out of the company and creates no dividend, because nothing is to be read into a taxing statute.
Tax and financial judgement · 9 Nov 2026 · 5 min read · Paid