Customs disputes are rarely won by argument alone. They are built on facts, evidence and a customs position that can be demonstrated from the records surrounding the transaction.
When Customs questions a declared value, the discussion should begin with the transaction itself: what was imported, what was agreed, what was paid or payable, and whether the records tell one coherent commercial story.
Beyond commodity transactions, MNEs often rely on intra-group financing arrangements, undertake business restructurings and maintain extensive documentation to support their transfer pricing positions.
Kenya's solar energy sector continues to attract interest from businesses and investors seeking to take advantage of the country's abundant solar resources and growing demand for reliable, sustainable energy.
The introduction of the Income Tax (Transfer Pricing) Rules, 2026 heralds a new era of compliance, reflective of evolving commercial realities and the increasing complexity of cross-border transactions.
