Founding Cohort Now Open — by application. Apply before July 31, 2026 →

Your finance team now knows what to do:
Africa Tax Terminal tracks & applies tax case law daily

Every Kenyan source of tax law - From the Tax Appeals Tribunal to the Supreme Court, KRA notices, EAC legislation, OECD guidance, Double Tax Agreements and the Constitution - all indexed into one evergreen knowledge base, checked continuously against your business' tax position, and certified by a named Tarra Agility Africa tax practitioner before it reaches you.

By application · Founding Cohort

ATT Health Check Finding — Expert Certified
Action required
High RiskCustoms

Every import needs an export declaration from the country of export from 1 September 2026 - or KRA can redetermine your customs value.

The Finance Act, 2026 inserts a new section 23B into the Tax Procedures Act, requiring every importer to obtain and retain, for five years, an export declaration or equivalent customs document from the country of export, with prescribed particulars. Where the importer cannot produce it, KRA may reject the declared value, origin, cost or ownership, redetermine the customs value and tax due, and impose administrative penalties. The obligation attaches to the goods, not to intent, good faith with a long-standing supplier does not help if the paperwork is not there.
Legal basis: Finance Act, 2026 (Act No. 19 of 2026), new s.23B, Tax Procedures Act · commencement 1 September 2026
Action Required

Identify every supplier from whom you will import after 1 September 2026. Write to each requesting the export declaration or equivalent document from their customs authority, with the prescribed particulars. Amend your standard purchase terms to make provision of the document a condition of payment. Configure five-year retention in your document management system.

37,533

Expert Derived Tax Rules & Principles
All applicable tax heads

48h

Tax Health Check Report issued after data submission
(Tax Expert Certified)

3 African Countries

Kenya live now,
Uganda & South Africa ongoing - Africa is next

6+

Next in line: Tanzania, Ghana, Nigeria
Zambia, Angola

Built by Tarra Agility - partners who argue these cases before the Tax Appeals Tribunal and the High Court of Kenya. Africa Tax Terminal is not merely a tax research tool, it surfaces tax issues relevant to your business based on sector risk and it ensures that the right people in the organisation know and do the right thing.

The knowledge base

One knowledge base - refreshed daily. Every source that binds you.

Most finance teams rely on KRA notices, a audit firm newsletters, annual tax health checks and WhatsApp group forwards. None of these is indexed to decided law - and the newsletter withholds the analysis until you pay for an engagement. Africa Tax Terminal indexes 5,426+ legal documents spanning the full hierarchy of Kenyan tax authority, updated as new law is published.

01

The Constitution of Kenya

The top of the hierarchy - and the limit behind every "interests of justice" argument at the Tribunal and High Court.

Indexed
02

Decided tax cases - Tribunal to Supreme Court

The binding interpretation of the statutes: Tax Appeals Tribunal, High Court, Court of Appeal and Supreme Court, indexed as decisions are published.

Indexed & Tax Rules Synthesized
03

KRA public notices, practice notes & alerts

The revenue authority's interpretation - held in its proper place: persuasive, not binding to the taxpayer but valuable insight.

Indexed & Tax Rules Synthesized
04

East African Community legislation

Including the Customs Management Act that governs every import and tariff-classification dispute. Treats the EAC as a single customs territory.

Indexed & Tax Rules Synthesized
05

OECD guidance & Kenya's Double Tax Agreements

The international layer over every cross-border and transfer-pricing position. Relevant for every cross border transaction, regardless of materiality.

Indexed & Tax Rules Synthesized
06

Tarra Agility expert-certified checklists & curated cases

Including decisions not yet indexed on eKLR -structured by the practitioners who argue them. This is the judgement call that needs to be taken when the law is not clear. An experienced practitioner weighs in.

Indexed & Tax Rules Synthesized

The hierarchy of authority

When a KRA notice and the Tribunal disagree, your team backs the notice.

That instinct is the exposure. A notice is only the revenue authority's interpretation - a Tribunal or court decision can override it. Knowing which source wins is exactly the training a finance team doesn't have. Africa Tax Terminal reasons from the top of the hierarchy down, and surfaces the conflict when a notice can't survive the decided law above it.

This is binding law

01

The Constitution

Supreme
02

Statute — ITA · VAT Act · TPA · EACCMA

Binding
03

Case law — SC → CoA → HC → Tribunal

Binding
04

KRA notices & practice notes

Interpretation

Where your team looks first

How ATT resolves a conflict

The team's position

A KRA practice note interprets a provision in the direction of collection. Working from the notice, your team files the position.

The decided law

A Tribunal or court reads the same statute differently — and sits above the notice in the hierarchy.

ATT surfaces

The decision binds. ATT flags that the notice does not survive it — before the filing becomes an assessment.

What every Kenyan CFO needs to know and implement at the finance team level

Three facts about tax in Kenya.

The law changes constantly - and binds immediately.

Finance Acts, Tribunal rulings, KRA notices and court judgments bind you the day they land. There is no grace period between a new precedent and your exposure.

Your finance team cannot track these legal changes and run the business at once.

No in-house team can run the business and monitor a legal landscape that shifts every quarter across six tax heads.

When KRA finds the gap, the clock has already been running. KRA uses this tax change to audit and assess additional taxes.

The burden of proof sits on you under s.56(1) of the Tax Procedures Act, and penalties run from the original obligation date - not the audit date, and not the date you raise your hand. Audits are adversarial and require careful assessment and expert support - your team shouldn't do it alone.

s.56(1)

The burden of proof is on you - not just to provide audited financial statements, but the supporting / underlying documents that corroborate the financial story.

Tax Procedures Act · TAT Act s.30

200%

Penalty on the tax avoided where a scheme is found to be tax avoidance.

Tax Procedures Act, s.85

5 yrs

KRA may amend without alleging fraud. Beyond five years, fraud or gross neglect must be shown.

Tax Procedures Act, s.31(4)

16 days

Late was enough to lose an entire appeal at the Tribunal.

Atta Kenya v CDT (TAT, 2025)

What a finding looks like

Grounded in a decided case — not a general principle.

Every ATT finding names the authority behind it: the case, the statute section, the notice. Your team can open the source and read it.

VATHigh risk

Your supplier's eTIMS failure is now your VAT liability. Input VAT is disallowed where the supplier cannot be verified — even where goods were delivered and paid for. Good faith is not a defence, and KRA cross-checks at the point of filing.

Legal basis: Gedi Boss Trading v CDT (TAT) · VAT Act, s.17(3) · KRA Public Notice

Transfer pricingContemporaneity

A KES 6.8 billion transfer-pricing assessment was defeated because the documentation was contemporaneous and specific to the entity's actual functions, assets and risks. Where a taxpayer's own TP policy mischaracterised its functions, the Commissioner's re-characterisation was upheld.

Legal basis: Wildlife Works Sanctuary v CLSBC (TAT, 2025) · ECP Kenya

ProcedureThe calendar

Appeals struck out for being 16 days late, months late, or for failing to attach the objection decision. And the mirror image: where the Commissioner misses the 60-day clock, the objection is deemed allowed by operation of law — a remedy only for the team that was tracking it.

Legal basis: Atta Kenya · Terrazzo · Kapiheri · Acer Petroleum · Atcost Structures

Ask the knowledge base

Ask the knowledge base directly.

Between reports, your team can ask Africa Tax Terminal a question in plain English and get an answer drawn only from the knowledge base - the 5,426 indexed legal documents, nothing from the open internet, nothing invented. All source documents are available in raw form.

  • Answers are specific to your sector, not generic guidance. The case law, KRA Notices and Tax Statutes are available in raw form.
  • Every response carries its source - available for cross reference. - the case, the statute section, or the notice it rests on. This allows the finance team the confidence that the advice is grounded on documentation you can rely on and cross reference.
  • Where a question turns on a genuinely uncertain area of law, it says so and routes you to a practitioner rather than forcing a false answer. The Tarra Agility tax expert supports the finance team to make a judgement call on the interpretation of a legal provision that does not fit squarely into the business circumstances.
The chat delivers grounded tax intelligence. Where a matter needs a formal opinion, that opinion is given separately by Tarra Agility Africa under engagement, signed, and carrying the professional responsibility that attaches to it.
ATT · Chat · Knowledge base only

Are management fees to our German parent fully deductible?

Not necessarily. Section 18(5) of the Income Tax Act restricts the deduction of management fees paid by a Kenyan permanent establishment to its head office — and this has been held to apply notwithstanding the double-tax agreement. The position turns on your specific structure.
Sources: Income Tax Act, s.18(5) · Aktiengesellschaft (TAT, 2024) · Kenya–Germany DTA
Note: this is a fact-specific area - a Tarra Agility practitioner can confirm on your structure.

The always-on health check

From your financial data to a certified finding.

The health check runs continuously, not once a year — so your team is never exposed to a risk that already has a decided case, a statute or a KRA notice behind it.

Stage 01

Data submission

You securely submit your trial balance, VAT returns, payroll, bank statements and intercompany agreements.

Stage 02

Knowledge base analysis

Your data is checked against the evergreen knowledge base — case law, statutes and KRA notices, current to the week.

Stage 03

Checks across six tax heads

VAT, CIT, PAYE, WHT, transfer pricing and customs — against 120+ expert-authored checklist items, each cited to source.

Stage 04

Expert certification

Every finding is reviewed and signed by a named Tarra Agility practitioner before the report reaches you.

Sector-specific · in your channels

The risk that matters to you is the risk in your sector.

A manufacturer's exposure on duty remission and tariff classification is not a bank's exposure on excise, and neither is an FMCG distributor's exposure on a long supplier list. ATT's analysis is worked sector by sector — so what reaches your team is the development that affects your business, not a general bulletin. And it reaches them where they already work.

WhatsApp — for the CFOMicrosoft TeamsSlack — for the finance teamEmail

What founding members say after their first health check.

"The TP finding alone — KES 12 million exposure we had not identified — justified the entire engagement within 48 hours of submitting our data. I sent the finding directly to our board."
CFO, Manufacturing subsidiaryNairobi (anonymised, consent obtained)
"What distinguished ATT from every other advisory engagement I have had is that they cited the actual case. Not a general principle — the actual decision, the TAT reference, the holding. That is a different product entirely."
Head of Legal, Financial Services groupNairobi (anonymised, consent obtained)
"We had been relying on our ERP's eTIMS integration and assumed it was covering us. The ATT health check identified 11 suppliers — KES 2.8M in input VAT — that were not on eTIMS. We had no idea."
Finance Director, FMCG subsidiaryNairobi (anonymised, consent obtained)

Where the global platforms stop

Your group has Bloomberg Tax.
Your Nairobi subsidiary has a PDF.

Bloomberg Tax, Thomson Reuters Checkpoint, Wolters Kluwer CCH, IBFD and Orbitax are the standing infrastructure of tax departments in London, New York and Frankfurt. They cover Kenya — at country-survey depth.

None of them indexes KETAT jurisprudence as decisions are published.
None of them transmits to eTIMS or reads Kenya's enforcement mechanics.
None of them holds African transfer-pricing comparables at usable depth.

The practitioners behind ATT

Named practitioners. Accountable for every finding.

ATT is not an anonymous algorithm. Service delivery is led by the Tarra Agility Africa tax team — the same practitioners who argue these matters before the Tribunal and the courts. The technology does the reading at a scale no human can. The judgment your board relies on stays human.

BO

Brian Otieno

Tax · Tarra Agility

BN

Beatrice Njeri

Tax · Tarra Agility

MK

Marjorie Kivuva

Tax · Tarra Agility

IL

Ivy Luusa

Tax · Tarra Agility

DM

Derrick Muchoki

Tax · Tarra Agility

EN

Eddah Nyamweya

Tax · Tarra Agility

WK

Winnie Kahara

Tax · Tarra Agility

VG

Valentine Gaya

Tax · Tarra Agility

Why your CFO and Head of Legal can trust the output

Source law only. Signed by a named expert.

Grounded in source law

Every citation comes from the curated knowledge base of decided cases, statutes and KRA notices — no open-internet sources, no generic summaries, no opinion content.

Source law only · verified citations

Expert certification

Every finding is reviewed and signed by a named, qualified practitioner before it is released. Findings are issued as tax intelligence; a formal opinion is given separately under engagement.

Named practitioner · digital signature

Document security

AES-256 at rest, TLS 1.3 in transit, row-level client isolation, zero-data-retention on every AI call, and automatic purge 90 days after delivery.

AES-256 · TLS 1.3 · ZDR enforced

Expert advisory delivered continuously — not once a year when it's too late.

For finance teams at multinationals and VC-backed firms. Up to 4 team members per subscription. Billed annually in advance.

Core

Always-On Tax Health Check

From $1,000

per year · 4 team members

  • Continuous tax exposure monitoring — not a one-off annual review
  • 30,000+ expert checks across all tax heads (VAT, CIT, PAYE, WHT, TP, Customs)
  • Every finding certified by a named Tarra Agility tax professional
  • Grounded in ATT's evergreen knowledge base — case law, statutes, KRA notices
  • Actionable findings with KES exposure estimates and legal basis
popular

Sector Intelligence

ATT Tax Sector Pulse

From $3,500

per year · 4 team members

  • Everything in the Always-On Tax Health Check
  • Industry-specific intelligence — Manufacturing, FS, FMCG, Telecoms, Energy
  • Sector-specific risk register, updated as law evolves
  • Transfer pricing compliance guide (OECD + local rules)
  • Audit defence handbook — case-backed checklist for your sector

Advisory

High-Touch Advisory

From $5,000

per year · custom scope

  • Everything in the Tax Sector Pulse
  • Buy-side and sell-side M&A tax due diligence
  • KRA audit defence and dispute support
  • Formal expert tax opinions — signed by qualified advocate
  • Direct access to Tarra Agility partners

The founding cohort is open — by application.

Annual subscription from $1,000 for a 4-member team. Founding members receive locked pricing for 24 months and priority access to Uganda and South Africa expansion.