Globally, tax laws have been evolving over time to keep pace with the changes in socio-economic and political spheres. These changes have been precipitated by the desire to protect and expand the tax base. Internationally, these changes are reflected in initiatives such as Base Erosion and Profit Shifting (BEPs), Transfer Pricing/Mispricing, Double Taxation/Non-taxation and the related Limitation of Benefits (LoB), among others.

Kenya on its part has not been left behind. We have recently witnessed unprecedented overhauls of some of our tax statutes as well as enactment of new pieces of substantive, procedural and administrative tax legislations, save for the Income Tax Act (ITA) which was enacted in 1973 to replace the Management Act.