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Kenya High Court rules technical fees are not taxable in source country unless recipient has PE in source country under Kenya-France DTA

|Tax Alerts, Legislation & Policy, Tr ...|France, Kenya
France, Kenya

  • Kenya's High Court has upheld the decision of the Tax Appeals Tribunal that technical fees under the Kenya-France DTA are taxable in the country of residence of the recipient unless where they have permanent establishment in the other state.
  • The Kenya-France DTA is modeled after both the OECD and UN Model Tax Conventions.
 

Executive summary

The High Court has upheld the position held by the Tax …

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