New dawn for certainty in transfer pricing and cooperation

VAT collections

Introducing APAs signals a deeper policy shift from adversarial tax enforcement towards cooperative compliance.

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The long-awaited proposal to introduce Advance Pricing Agreements (APAs) regime in Kenya with a five-year limit, through the Finance Bill 2025, marks a significant shift in the country’s approach to transfer pricing (TP) regulation and fosters greater predictability.

This milestone will credentialise Kenya as a premier investment hub. As multinational enterprises (MNEs) continue to expand operations across African markets, Kenya is positioning itself as a jurisdiction that not only enforces tax rules but also provides mechanisms for certainty and cooperation.

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Note: The results are not exact but very close to the actual.