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Kenya High Court: No Withholding Tax on Management and Professional Service Fees under Kenya-France Treaty

|Treaty Development|Kenya-France
Kenya-France

The Kenya High Court on 4 July 2024 rendered its decision in Case E044 – Commissioner of Domestic Taxes vs. Total Kenya Limited. The case dealt with the issue of whether or not Kenya may levy a withholding tax on technical management and professional services fees paid by a Kenyan subsidiary to its French parent company, the oil major Total. The Kenya Revenue Service took the position that tech…

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