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 summaryThe High Court has upheld the position held by the Tax Appeals Tribunal (TAT) on the taxation of technical fees under the Kenya-France Double Tax Agreement (DTA).The High Court held that, based on the Kenya-France DTA, technical fees are subject to income tax in the country of residence...