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Why transfer pricing disputes need fair play, not perfection
Priority should be given to a cohesive commercial narrative rather than granular details. Does the documentation reflect business reality? Does the TP method match the functions performed? Is the benchmarking grounded in accepted practice?
Transfer pricing (TP) has become one of the most contested areas in Kenya’s tax system. The Tax Appeals Tribunal continues to hear high-stakes TP disputes in steady succession.
Recent data shows that in one review cycle alone, the Tribunal decided 38 cases across multiple tax categories, demonstrating the pace and pressure of tax dispute resolution in Kenya.
