This alert brings to your attention the recent decision, by the Tax Appeals Tribunal in the case of African Banking Corporation Limited -versus- Commissioner of Domestic Taxes (Tribunal Appeal E1324 of 2025) [2026] KETAT 162 (KLR) (13 July 2026) (Judgment).
In summary, the Tribunal held that:
Although corporate sponsorships may, in principle, qualify as deductible marketing and advertising expenditure, the Tribunal found that the taxpayer had not provided sufficient evidence linking the disputed CSR expenditure to a commercial purpose and identifiable marketing deliverables.
KRA’s apportionment of interest and operating expenses to exempt infrastructure bond income is speculative and without factual foundation.
KPMG Tax Alert - Tribunal Clarifies Deductibility of CSR Expenses and Cost Attribution to-Exempt-Income
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Sandeep Main
Partner, Tax & Regulatory Services and Africa Head of Private Enterprise
KPMG One Africa
