OECD · BEPS · Transfer Pricing · Treaties

International
Tax Advisory

Cross-border tax structuring, transfer pricing documentation, double tax treaty analysis, and BEPS compliance ’ for multinationals entering East Africa and Kenyan businesses expanding globally.

East Africa's Gateway Tax Advisors

Cross-Border Tax. Managed
With Local Precision.

International tax in East Africa has never been more complex or more scrutinised. Kenya's adoption of BEPS minimum standards, KRA's aggressive transfer pricing enforcement, the introduction of digital service tax, and the expanding network of double tax agreements have fundamentally changed the risk landscape for cross-border businesses.

Brezoid advises multinationals entering Kenya, Kenyan groups expanding regionally, and East African subsidiaries of global corporations. Our international tax team has OECD transfer pricing training, direct experience of KRA's TP audit methodology, and established correspondent relationships across Uganda, Tanzania, Rwanda, and beyond.

We don't just prepare documentation. We build defensible, commercially rational positions ’ because KRA's transfer pricing unit is sophisticated, well-resourced, and increasingly aggressive in challenging intra-group arrangements.

Service Facts

PricingOn request
TP standardOECD Guidelines
Countries coveredEast Africa + global
KRA TP experience15+ years
Engagement leadBrenda Nyaboke Okerosi
Request a Consultation Speak to the Int'l Tax Partner
International Tax Practice

Five Cross-Border Tax Specialisms

Transfer Pricing

Full transfer pricing documentation compliant with Kenya's Income Tax (Transfer Pricing) Rules and the OECD Guidelines ’ including benchmarking studies, master file, and local file preparation.

  • TP policy design & documentation
  • Benchmarking & comparables analysis
  • Master file & local file
  • Country-by-Country Reporting
  • KRA TP audit defence

Double Tax Treaty Analysis

Interpreting Kenya's network of double tax agreements to minimise withholding taxes on dividends, interest, royalties, and service fees ’ and advising on treaty eligibility and LOB provisions.

  • WHT reduction analysis
  • Permanent establishment review
  • LOB & PPT provisions
  • Treaty shopping risk assessment

BEPS Compliance

Kenya has adopted all OECD BEPS minimum standards. We advise on Action Plan compliance ’ from country-by-country reporting to hybrid mismatch rules and preventing treaty abuse.

  • BEPS gap analysis
  • Hybrid mismatch planning
  • CbCR preparation & filing
  • Substance requirements

Inbound & Outbound Structuring

Tax-efficient structures for foreign investors entering Kenya and Kenyan businesses expanding regionally ’ minimising effective tax rates while maintaining regulatory compliance.

  • Entry structure optimisation
  • Holding company jurisdiction
  • Repatriation planning
  • Regional operating models

Digital Services Tax & PE

Kenya's Digital Service Tax applies to non-resident digital marketplace operators. We advise on DST registration, compliance obligations, and the intersection with permanent establishment rules.

  • DST registration & filing
  • PE exposure assessment
  • Platform economy taxation
  • Significant economic presence
Kenya's Treaty Network

Double Tax Agreements
We Work With Daily

Kenya has an active and expanding DTT network. We maintain current analysis of each treaty and monitor ongoing EAC harmonisation initiatives.

UK

United Kingdom

WHT: Dividends 15% / Interest 15% / Royalties 15%

Active
IN

India

WHT: Dividends 15% / Interest 15% / Royalties 20%

Active
DE

Germany

WHT: Dividends 15% / Interest 15% / Royalties 15%

Active
FR

France

WHT: Dividends 10% / Interest 12% / Royalties 10%

Active
ZA

South Africa

WHT: Dividends 10% / Interest 10% / Royalties 10%

Active
CA

Canada

WHT: Dividends 15“25% / Interest 15% / Royalties 15%

Active
QA

Qatar

WHT: Dividends 5% / Interest 10% / Royalties 10%

Active
AE

UAE

WHT: Dividends 5% / Interest 10% / Royalties 10%

Active

* WHT rates shown are treaty rates. Domestic rates apply absent treaty. All rates subject to LOB/PPT provisions and beneficial ownership requirements.

BEPS Minimum Standards

OECD BEPS Actions
We Advise On

Action 5

Harmful Tax Practices

Transparency frameworks and substance requirements for preferential regimes.

Action 6

Treaty Abuse Prevention

PPT and LOB provisions in Kenya's updated treaty network.

Action 13

Transfer Pricing Documentation

Master file, local file, and CbCR preparation and filing.

Action 14

Dispute Resolution

MAP (Mutual Agreement Procedure) access and effectiveness.

Pillar 2

Global Minimum Tax (15%)

Impact assessment for MNE groups with Kenyan operations above —750M threshold.

East African Countries We Cover

Kenya Uganda Tanzania Rwanda Ethiopia DRC South Sudan

Our Correspondent Network

We maintain active correspondent relationships with local tax advisors in Uganda, Tanzania, and Rwanda ’ enabling us to provide seamless pan-East African advice without referring you elsewhere.

Ask about regional coverage

Tax Advisory

Domestic planning alongside international.

Auditing

Group audit for multinational entities.

Business Registration

Kenya entity setup for inbound investors.

Operating Across Borders? Let's Talk.

Book a confidential consultation with our International Tax Partner. We'll assess your cross-border exposure and identify the priority issues within 48 hours.

Book a Consultation Speak to the Int'l Tax Team