Tax systems and policies

August 2025

5 Questions

Question 4b

In an era of evolving tax framework, self-regulation of tax professionals by recognised professional bodies is an important component of the countries tax administration system in maintaining the integrity of the tax system.

Required:

Analyse FOUR benefits of having self-regulation of tax professionals by professional bodies over government oversight.

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Question 4a

During a tax seminar on “mitigating tax exposures”, the key note speaker observed that tax risk management plays a critical role in the development of tax planning strategies for an organisation.

Required:

(i) Summarise FOUR ways that a tax professional could use to quantify tax risk in an organisation.

(ii) Evaluate FOUR roles of tax risk management in the development of tax planning strategies of an organisation.

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Question 1a

You have been appointed as a tax advisor to a contractor involved in infrastructure projects for a County Government. The contractor has recently received conflicting tax assessment from both the Revenue Authority relating to withholding tax and County Government relating to contractual service levy. The contractor believes the charges are duplicative and not grounded in clear provisions. The delays in resolving the dispute have stalled payments and strained the contractor’s cash flows.

Required:

(i) Explain the tax dispute resolution mechanism available to the contractor under Kenyan tax laws.

(ii) Advise the contractor on the steps to take in resolving the tax dispute with the Revenue Authority and County Government.

(iii) Propose FOUR institutional reforms that the County Government could implement to avoid similar tax disputes with contractors in the future.

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Question 5a

In the context of tax compliance and advisory, the roles of a tax agent and tax representative are different yet they overlap.

With reference to the above statement, explain TWO distinguishing factors between a “tax agent” and a “tax representative”.

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Question 5b

Tax amnesty programs are used by countries in formulating tax policies to encourage tax compliance.

In relation to the above statement, evaluate FOUR limitations of using tax amnesty by a country.

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April 2025

2 Questions

Question 5b

Analyse FOUR reasons for the introduction of tax anti-avoidance provisions despite tax avoidance being a legal activity.

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Question 1b

Technology in tax administration fosters a more transparent, accountable and efficient tax system as well as facilitating tax expansion benefiting both the government and taxpayers. This can be enhanced through incorporating the use of artificial intelligence commonly referred to as “AI” in tax administration.

Required:

Evaluate FIVE ways in which the use of Artificial Intelligence could be used to enhance tax administration in your country.

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December 2024

4 Questions

Question 3a

Government provides various tax incentives to both individuals and entities with the intention of achieving various tax policy objectives. Analyse TWO tax incentives provided by the government to encourage home ownership in your country.

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Question 3b

Tax Information Exchange Agreements (TIEAs) are bilateral agreements between two countries aimed at improving tax compliance and reducing tax evasion. While TIEAs are intended to enhance transparency and ensure that taxpayers are meeting their obligations through information sharing, they also present challenges for developing countries.

Required:

Argue FOUR cases against Tax Information Exchange Agreements (TIEAs) that are encountered by developing countries.

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Question 5a

The taxation of capital gains in Kenya represents a significant shift in the country’s tax policy. While its reintroduction has increased government revenue and aligned Kenya with international practices, it also presents challenges. Hence ongoing improvements and adjustments in its administration is crucial for optimising the benefits of capital gains tax while minimising its drawbacks.

Required:

(i) Analyse TWO circumstances that constitute transfer of property for purpose of computing Capital Gains Tax.

(ii) Explain TWO challenges encountered in administration of Capital Gains Tax in your country.

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Question 5b

In a tax seminar, one of the facilitators noted that, “generally there are two main types of tax systems that are adopted by different countries, that is, unified tax system and multiple tax systems”.

With reference to the above statement, argue THREE cases against multiple tax systems adopted by different countries.

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August 2024

3 Questions

Question 4a

The Revenue Authority of your country is under pressure from the national government to enhance the tax collection and administration efficiency in a bid to raise sufficient revenue.

To this end the revenue authority is considering adopting the tax base expansion strategies.

Required:

Advise the commissioner in charge of the revenue authority on FIVE tax base expansion strategies that the revenue authority could adopt.

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Question 5a

Evaluate FOUR ethical issues that policy makers are required to consider when designing tax systems.

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Question 5b

In a tax seminar one of the facilitators noted that “most governments in developing countries are faced with challenges of regulating and combating the use of tax haven”.

With reference to the above statement, analyse FIVE challenges faced by governments in regulating and combating the use of tax havens.

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April 2024

6 Questions

Question 4b

John Pritt, a citizen of Rwanda has received two job offers in Kenya for which he has approached you to advise on which job offer to accept.

Job offer A:

John Pritt would be employed as a finance officer with African Airway Ltd., a regional airline with its head office in Kenya. The offer provided for the following:

Basic salary of Sh.130,000 per month to be increased semi-annually by 10%.
A monthly bonus of 5% of the basic salary to be paid on the ninth day of the following month.
Fuel allowance of Sh.10 per kilometer where he is estimated to be covering 10,000 kilometers in a year, three quarters of which will be on official duties.
He will be provided with free return air ticket worth Sh.16,000 for each travel on 30 June and 31 December each year to visit his family in Rwanda.
The company will provide him with a house whose market rental value is Sh.30,000 per month.
The employer will deduct Sh.5,000 per month as rent. The house will be fully furnished at a cost of Sh.480,000.

Job offer B.

John Pritt would be employed as an accountant by Watts Ltd. The offer provides for:

Basic salary of Sh.145,000 per month and an allowance of Sh.5,000 per month for attending finance committee meetings.
An annual allowance of Sh.150,000 for the purchase of office attire in line with the company’s dress code.
A provision for sending him to their Uganda office on a one month per year job rotation. He will be sent to Uganda in November every year and he will receive his monthly pay as usual. During that month he will attend the finance committee meeting as planned in Kenya, as the company will facilitate him with a return air ticket.
He will be provided with a saloon car costing Sh.2,800,000 of 3000 cc.
The company will cater for his night watchman’s monthly salary of Sh.18,000. His monthly water bills and electricity bills will also be paid by the company.

Required:

(i) Evaluate the two job offers and advise John Pritt on which job offer to accept based on net annual income using the tax rates for the year 2023 as provided in the tax table.

(ii) Advise John Pritt on FOUR conditions that one is required to meet in order to qualify for double taxation relief in Kenya or your country.

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Question 1a

SpeedTech Corporation is a multinational technology company operating in Kenya. The company provides digital services to consumers in the country.

Required:

Analyse the impact of digital service tax on SpeedTech Corporation’s operations in Kenya.

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Question 2a

Explain THREE benefits emanating from the recent changes in Tax Dispute Resolution Mechanisms on taxpayer adherence to regulations and the efficiency of administrative processes in Kenya.

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Question 2b

Describe FOUR strategies employed by multinational corporations in mitigating complex tax risks during corporate restructuring across multiple jurisdictions.

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Question 3a

Explain THREE tax reforms aimed at promoting investment and economic growth while ensuring fairness and equity in taxation in your country.

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Question 5a

Explain FOUR initiatives undertaken by the revenue authority in your country to entrench ethics and integrity in administration of tax.

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December 2023

4 Questions

Question 5a

In a tax dispute resolution mechanism workshop, one of the facilitators noted that, “there is need for establishing a specialised tax court within the country to handle tax appeals from the Tax Appeals Tribunal”. Justify the above statement, citing THREE benefits that could be derived from establishing a specialised tax court.

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Question 2a

Tax agents play a crucial role in helping micro and small enterprises (MSEs) comply with tax obligations.

In light of the above statement, explain THREE potential areas the revenue authority may collaborate with tax agents to bridge tax gaps in MSEs in your country.

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Question 1a

Assume that you work for a tax consultancy firm. A client, Masterway Ltd., intends to develop a Transfer Pricing Policy document and has approached your firm for advice on information that it should include in the document.

Required:

Advise Masterway Ltd. on FOUR items that should be included in a transfer pricing policy document.

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Question 3b

Explain how the adoption of the following policy frameworks would strengthen revenue mobilisation in your country:

(i) Fiscal policy options.

(ii) Tax policy options.

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August 2023

9 Questions

Question 3c

The Revenue Authority of your country intends to introduce a tax on digital assets in the next government budget. During public participation forums, most citizens rejected the proposed digital tax since they were not conversant with digital assets.

Citing an example, explain what “digital assets” entail.

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Question 1a

Discuss how the following issues may generate ethical dilemmas to a tax professional:

(i) Conflict of interest.

(ii) Contingent fee tax representations.

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Question 1b

Describe THREE criteria for evaluating modern tax systems.

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Question 1d

Citing FOUR reasons, argue the case for double taxation agreements as tax incentives.

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Question 5c

Johnson Shauri has not been maintaining proper books of accounts since the inception of his business in year 2019. The following balances were obtained from the available business records for the four year period ended 31 December 2022:

	31 December 2019	31 December 2020	31 December 2021	31 December 2022
	Sh.“000”	Sh.“000”	Sh.“000”	Sh.“000”
Leasehold property	11,760	11,760	11,760	11,760
Motor vehicles	5,040	4,720	9,360	10,760
Furniture	864	864	864	864
Bank overdraft	1,288	1,400	1,210	1,115
Loss on sale of investment	-	100	-	-
Accounts receivable	432	504	408	600
Mortgage loan	2,080	1,840	1,620	1,500
Inventory	620	572	482	520
Computers	620	720	840	720
Bank account	240	268	272	286
Personal clothes and effects	60	80	100	120

The following additional information was obtained:

Drawings of goods and provision for taxation for the year 2019 were Sh.600,000 and Sh.360,000 respectively and has been accumulating at a rate of 10% annually.
Capital allowances were agreed at a total of Sh.920,000 for each of the four years.
Donations to a political party in the year 2020 amounted to Sh.142,000.
Gifts from relatives for the year 2021 were Sh.840,000.
Contingent liability in respect of a pending court case in the year 2022 was Sh.1,000,000.
Rent paid on behalf of a close friend was Sh.605,000 in the year 2022.
Living expenses were estimated at Sh.800,000 in the year 2019 and had been increasing at the rate of 15% cumulatively each year.

Required:

(i) Compute the taxable income or loss of Johnson Shauri for the three-year period ended 31 December 2020, 2021 and 2022.

(ii) Summarise THREE specific actions that a tax practitioner could undertake upon discovery of an irregularity in the client’s business.

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Question 5a

Explain THREE reasons why investment allowances as tax incentives have not achieved the intended objectives in your country.

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Question 4b

KK Realtors are in the real estate business. They rent out two prime highrise buildings, one a residential apartment and the other an office block. They are registered for the monthly residential rental obligation as well as filing for value added tax (VAT).

Details of their transactions for the month of December 2022 are provided below:

Incomes	Sh.“000”
Rent: Apartment	1,248,450
Rent: Office block	7,244,200
Expenses:
Garbage collection	75,864
Sewerage	92,8090
Repairs and maintenance (outsourced to local company)	144,420
Housing agents fee (5% of income)	?
Security firm (eight day and eight night guards)	464,000
Insurance	580,000
Interest on bank loan	139,200
Caretakers’ salaries	92,800
Webhosting (by South Africa-based company)	67,280
Audit and assurance fee	1,334,000
Telephone and electricity	52,952
Other staff salaries	992,496
Architect’s fee (based in France)	184,730

The following additional information is provided:

1. With the exception of housing agents fee, webhosting and architect’s fee, a quarter of the expenses relate to the residential business while the rest relate to the office block. 2. Housing agents fee accrues based on the amount paid for income collected from each property.

3. Webhosting and architects fee could not be directly attributed to either the residential apartment or office block.

4. Tenants of the office block are agents for withholding value added tax (VAT) and withholding rental income.

5. The figures provided are quoted inclusive of VAT where applicable.

Required:

(i) Calculate the tax payable under the VAT and income tax obligations by KK Realtors for the month of December 2022.

(ii) Show the withholding tax collected under the obligations in (b)(i) above, if any, as well as the net rent income received by KK Realtors, as cash.

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Question 4a

Assume that your country has continued to face challenges in addressing tax deficits. Over the past few years, the revenue from taxation has not fully met the country’s development needs.

Required:

As a tax expert, advise the revenue authority in your country on FIVE possible reasons for the shortfall in tax collection.

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Question 2c

Analyse the Income Tax Act provisions in relation to taxation of collective investment schemes.

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April 2023

4 Questions

Question 5a

The Revenue Authority of your country has been undertaking tax reforms in a bid to improve tax collection and tax compliance. To this end, the Authority has formulated a three-year corporate plan that runs from the year 2021/2022 – 2023/2024. So far, most of the corporate plan priorities remain elusive and hence the Revenue Authority has not been able to achieve most of its strategic objectives.

Required:

Analyse FOUR reasons that may have contributed to the Revenue Authority being unable to achieve the strategic objectives.

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Question 2c

The national treasury in your country recently issued a draft national tax policy for public participation and discussion.

Required:

(i) Explain THREE objectives of a national tax policy.

(ii) Describe THREE practical challenges that a national tax policy is aimed at addressing.

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Question 2a

During the period between 1 July 2015 and 30 June 2020, Chris Alexo earned income of Sh.18,000,000 which he did not declare to the revenue authority. The tax thereon amounted to Sh.6,000,000 with penalties and interest of Sh.1,500,000 and Sh.600,000 respectively. In the year 2021, Chris Alexo applied for relief under the voluntary tax disclosure programme (VTDP) and the approval was done in August the same year. He thereafter paid Sh.3,000,000 to offset the tax due. During the year ended 31 December 2022, Chris Alexo settled Sh.1,500,000 of the principal tax but accrued further penalties of Sh.250,000 and interest of Sh.100,000. He estimates that he can only pay Sh.1,000,000 during the year 2023. This will result into additional penalties and interest of Sh.100,000 and Sh.60,000 respectively.

Required:

Compute the tax, penalties and interest (if any) for the relevant years to be waived or paid by Chris Alexo under the VTDP.

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Question 1a

Analyse FOUR roles of an arbiter in a tax alternative dispute resolution (ADR) process.

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December 2022

1 Questions

Question 3b

The Commissioner is empowered to cancel or terminate the license of any person acting as a tax agent at any time. Summarise FOUR circumstances under which this may be possible.

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August 2022

4 Questions

Question 3b

Explain four measures that a tax revenue authority might adopt to reduce tax gaps or revenue leakages in taxation of the digital economy.

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Question 5b

In the recent months, the Revenue Authority reports have indicated achievement of tax collection targets.

Required:

Explore the factors that might have led to this achievement.

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Question 5a

A recent publication from a leading international advisory group opines that, of all forms of tax incentives, tax holidays are the most popular among developing countries.

Required:

Discuss four limitations of tax holidays in developing countries.

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Question 3c

Explain the tax implications of the following:

(i) Where two or more entities enter into a joint venture agreement or partnership.

(ii) Where shareholders are wholly or partly paid in cash for forfeiting their shares in a cessation of business.

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April 2022

4 Questions

Question 4a

You have been engaged by the revenue authority in your country to develop a stakeholder engagement action plan. This is part of the measures to enhance tax awareness, increase compliance and enhance efficiency in tax administration.

Required:

Discuss the stakeholder engagement processes or initiatives that you would include in your action plan, including the objective of each process or initiative.

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Question 1a

The following facts relating to a hypothetical tax case in your country have been presented to you. The case related to the applicability of withholding tax on interest accrued in the audited books of a taxpayer.

1.	Ale Ltd. entered into an agreement with a contractor under which it agreed to pay interest on any contractual fees paid late. A number of payments due to the contractor were delayed and incurred interest. The interest was not actually paid but the obligation to pay was accrued as a liability in the respondent's books.
2.	As interest is a business expense, Ale Ltd. expensed it as a tax deductible item thereby reducing its corporation tax liability. The revenue authority undertook an audit and demanded payment on the withholding tax on the accrued interest. Following the demand, Ale Ltd. filed the matter before a tax tribunal.
3.	The revenue authority claimed that by recognising accrued interest as a liability in its books of account, Ale Ltd. acknowledged that interest was credited to the account of the third party and therefore fell within the definition of the term "paid" under applicable tax laws.
4.	At the tax tribunal, Ale Ltd. presented the following arguments: The term "paid" in tax law can only mean delivery of money and discharge of settlement. Since Ale Ltd. neither settled the outstanding contractual fee nor paid any interest charged, even though the interest was recognised as a liability in its books of account, no withholding tax was due for that transaction. As per tax laws, tax is withheld upon payment of the expenses thus payment is a necessary pre-requisite for withholding tax to apply. The settlement of an obligation may be through receipt of cash, cheque or other mode of settlement or discharge and an accrual is therefore not a discharge of a debt. Payment denotes the discharge of a debt or liability and it was premature for the revenue authority to demand payment of the withholding tax before the actual payment of interest. By doing so, the revenue authority clearly exceeded its powers.

Required:

As a Certified Public Accountant and tax expert, you have been engaged by the revenue authority to counter the arguments by Ale Ltd. for consideration by the Tax Tribunal.

Prepare your professional opinion making reference to the facts above, applicable tax laws and decided tax cases to support your position.

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Question 5a

Describe four constraints faced by the revenue authority in your country in the assessment and collection of taxes from the micro, small and medium enterprises (MSMEs).

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Question 5b

Discuss how the revenue authority of your country might deal with taxpayers' apathy in filing tax returns. (

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Pilot December 2021

4 Questions

Question 5b

Customs audit is the process of verifying that the business is in compliance with the customs legislation through the examination of books and records of a business to prevent commercial fraud.

In relation to the above statement, explain the objectives of a customs audit.

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Question 5a

Explain the challenges in implementing special economic zones (SEZs).

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Question 4b(i)

In Kenya, tax agents are individuals or companies that prepare taxes on behalf of the tax payers, they also offers professional assistance to people or companies that do not want to prepare taxes on their own.

In light of the above statement, explain circumstances under which a tax agent’s license may be canceled.

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Question 2b

Explain the meaning of thin capitalisation in relation to an entity.

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December 2021

4 Questions

Question 4a

Describe the features that indicate the possible existence of a tax haven.

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Question 3a

You have been appointed as the first tax consultant of ABC International PLC, a newly incorporated company in your country.

Required:

Draft a letter to the Revenue Authority for income tax registration for ABC International PLC.

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Question 1b

A delegation comprising government officials and entrepreneurs from a neighbouring country has visited your country, which is a beneficiary of the African Growth and Opportunity Act (AGOA) to learn more on AGOA and its benefits.

Required:

Prepare a brief to be presented to the delegation covering the following:

(i) Background information on AGOA.

(ii) Conditions to be considered as an AGOA beneficiary country.

(iii) Trade benefits provided under AGOA.

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Question 1a

As economies continue to recover from the impact of the COVID-19 pandemic, tax collection in many countries continues to face challenges. This trend has resulted in some revenue authorities resorting to some drastic measures to boost tax revenue.

One recent measure taken is monitoring of social media accounts and postings to assess taxation compliance.

Required:

Justifying your response with practical reasons, argue the case for or against monitoring of social media accounts to assess taxable capacity and compliance. (Note: marks will be awarded for only one position taken).

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September 2021

3 Questions

Question 3a

The resource mobilisation department is instrumental in enabling the government to execute its mandate and responsibilities to the citizens.

Required:

Evaluate the roles played by the resource mobilisation department in the National Treasury or a similar body in your country.

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Question 2b

There are clear differences between debt management in the private sector and in the public sector. However, the main objective of debt management in both sectors is the sustainability of the institutions concerned.

Required:

Describe the salient features that distinguish debt management in the public sector as compared to the private sector.

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Question 1a

One of the recent trends in the field of taxation is the introduction of digital services tax (DST).

Required:

(i) Explain the meaning and operations of the digital services tax (DST).

(ii) Describe three types of transactions where DST is applicable.

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May 2021

3 Questions

Question 5c

Explain two ways through which proper tax planning may contribute to economic stability of a country.

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Question 3a

Citing examples, differentiate between a "tax waiver" and a "tax amnesty.

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Question 1b

During a conference held by the Organisation for Economic Co-operation and Development (OECD) on policies for rebuilding post covid-19 economies, one speaker noted that "once countries stabilise their fiscal recoveries amid the Corona virus crisis, they should seize the chance to build their economies through taxation policy".

Required:

Evaluate six tax policy measures that developing countries should adopt for rebuilding Post-Covid 19 economies.

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November 2020

3 Questions

Question 1d

Taxation has generally contributed to economic development and empowerment of the population in most countries However, taxation may also result in certain negative consequences on the society

Required:

Discuss three negative impacts of taxation in a country

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Question 3b

Citing four reasons, argue the case forcontinued provision oftax incentives by a country that is experiencing budget deficits.

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Question 4a

Describe four tax policy challenges that the government is facing in the taxation of digital economy in your country

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May 2019

2 Questions

Question 3c

Explain four benefits that might accrue from the effective use of information communication technology (ICT) in tax administration.

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Question 1a

Many governments particularly in developing countries have implemented various taxation policies to achieve fiscal and other objectives. Unfortunately, in some of these countries, the noble objectives of the taxation policies appear not to have been realised.

Required:

Evaluate four reasons which, in your assessment, have contributed to the failure of taxation policies to achieve their intended objectives.

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November 2018

1 Questions

Question 2b

Highlight four reasons why capital allowances as tax incentives might not have achieved their intended objective to the government in your country.

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May 2018

1 Questions

Question 4b

The revenue authority in your country recently established a Medium Taxpayers Office (MTO) as part of the tax reforms.

Required:

Discuss five objectives of the MТО.

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May 2017

1 Questions

Question 5a

The development of an effective tax policy for a country requires critical consideration of certain factors at macro- economic level.

Required:

Discuss such factors

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November 2016

1 Questions

Question 4a

Some scholars have raised concern over the apparent mismatch between taxation policy and the economic agenda of certain countries, where increased tax revenue did not necessarily translate into higher standards of living for the citizenry.

Required:

Explain four factors that could have contributed to the above scenario.

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May 2015

1 Questions

Question 5a

Discuss for limitations of taxation policy in attaining the macro-economic objectives of a country

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Tax systems and policies

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