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CPA Advanced Taxation – April 2026 Past Paper & Answers

Unit: Advanced Taxation

12 Questions

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Download CPA Advanced Taxation April 2026 past paper with detailed answers and marking scheme. This paper is based on KASNEB examination standards and is ideal for revision and exam preparation.

Access the full paper online, download the PDF, or study offline. Each question includes step-by-step solutions to help you understand key concepts in Advanced Taxation.

1a
Professional practice in taxation
​​Professional tax practitioners often find themselves in conflict between their duty of confidentiality to the client and their legal obligations under the Tax Procedures Act, regarding the disclosure of information to the Commissioner. 

Required: 
Evaluate THREE ethical dilemmas a practitioner faces when discovering a client has deliberately undervalued imported goods to evade Customs Duty and Value Added Tax, citing how a practitioner should balance client privilege with the statutory power of the Commissioner to enter premises and seize evidence under Section 60 of the Act.
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1b
Taxation of business income and specialized business activities
​ ​ ​ ​ ​ ​​Balala and Halali have been in a partnership since 1 January 2023, sharing profits and losses in the ratio of 3:2. On 1 July 2025, they admitted Busita as a partner and the profit-sharing ratio became 2:2:1. On 1 October 2025, the firm was converted into a limited liability company, Zawadi Ltd. The partners had not been keeping proper books of account. 

The following reconstructed information is available for the year ended 31 December 2025: 

 Summary of bank transactions:

ReceiptsSh."000"PaymentsSh."000"
Balance brought forward (1 January 2025)5,200Trade creditors28,400
Receipts from trade debtors54,000Rent (including deposit)4,200
Cash sales (banked)12,800Purchase of Mercedes Benz9,600
Sale of old delivery van1,100Neon sign and digital security system2,400
-Legal fees800
-General office expenses8,500
-Staff salaries (Net of PAYE)14,200
-Balance carried forward (31 December 2025)5,000
73,10073,100

Additional Information:
1. Technical analysis revealed that total sales and purchases were found to be undercast by 20% in the reconstructed records.
2. Trade debtors as at 1 January 2025 and 31 December 2025 were Sh.4.5 million and Sh.7.2 million respectively, while trade creditors were Sh.3.1 million and Sh.4.8 million respectively.
3. General office expenses included: Sh.400,000 donation to a registered political party; Sh.250,000 for e-TIMS accounting server and Sh.600,000 for a non-resident consultant’s digital system support.
4. Partner salaries before conversion: Sh.3.6 million (allocated equally). After conversion, directors’ fees paid amounted to Sh.1.2 million.
5. During the year, the partners withdrew goods for personal use originally included in bulk purchases. These were valued at cost price of Sh.600,000 for Balala and Sh.400,000 for Halali.
6. Zawadi Ltd. issued 12% debentures of Sh.10 million to an external investor upon its conversion on 1 October 2025.
7. Restructuring and Capital Gains Tax: On 1 October 2025, the partnership transferred freehold land (Cost Sh.15 million, market value Sh.25 million) to Zawadi Ltd. The partners maintained identical shareholding proportions in the new company.
8. Social Health Insurance Fund (SHIF): Staff salaries include Sh.450,000 in contributions made by the firm to the SHIF on behalf of employees.
9. e-TIMS Compliance: Purchases worth Sh. 2.8 million were from a small-scale supplier who did not issue e-TIMS invoices. The firm issued its own tax invoices as provided under Section 23A of the Tax Procedures Act.

Required:
(i) A statement showing the adjusted taxable profit or loss for the Partnership and Zawadi Ltd. for the year ended 31 December 2025 in a columnar format.

(ii) Total taxable income for each partner for the year ended 31 December 2025.  
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2a
Limited companies
​​Under Section 7A of the Income Tax Act, tax is chargeable on dividends distributed out of untaxed gains or profits. 

Required: 
Analyse the circumstances under which a company becomes liable to tax on distributed dividends, citing how the shortfall distribution tax mechanism is intended to discourage excessive retention of profits.
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2b
Limited companies
​​Platinum Holdings Ltd., is a Kenyan resident company with a 100% shareholding in Chilley Ltd., and a Branch in Tanzania. The group’s consolidated annual turnover is Sh.120 billion. The results for the year ended 31 December 2025 was as follows:

Platinum Ltd.
Chilley Ltd.Tanzania Branch
(Head Quarter-HQ)
Sh."000"Sh."000"Sh."000"
Gross profit1,460,000720,000480,000
Management fees (from Tanzania Branch.)80,000--
Expenses:
Staff costs280,000165,00095,000
Interest (Non-resident bank)110,00096,00042,000
Depreciation74,00058,00031,000
Legal fees22,40011,5006,800
Earnings Before Interest, Tax,-320,000-
Depreciation and Amortisation---
(EBITDA)---

Additional information:
1. Chilley Ltd.'s interest of Sh.96 million was to a non-resident bank. EBITDA was Sh.320 million.
2. Legal fees for Platinum Ltd. included Sh. 8 million for trademark infringement and Sh.5 million for an environmental audit.
3. Platinum Ltd. sold inventory to Chilley Ltd. at a 25% markup. Inventory worth Sh.140 million remained in Chilley’s Ltd. stores at year-end.
4. Tanzania branch Corporate Tax was paid in Tanzania at 30%. Assume Kenya has a Double Taxation Agreement (DTA) with Tanzania. And that the amount under Tanzania Branch is stated in Kenya shillings.
5. Platinum Ltd’s. staff costs include Sh.15 million for an unregistered pension scheme and Sh.12 million direct gratuity payments.
6. Platinum Ltd. sold an office building for Sh.60 million (cost Sh. 40 million, net book value Sh.25 million).
7. Platinum Ltd. management fees of Sh.80 million (gross) were subject to 15% withholding tax in Tanzania under the DTA.
8. The group is required to file a Master File and Local File as provided under the Income Tax Act as its consolidated turnover exceeds the Sh.95 billion threshold.

Required:
(i) Compute the taxable income and tax payable for Platinum Holdings Ltd. (Consolidating HQ and Branch) for the year ended 31 December 2025. 

(ii) Compute the taxable profit for Chilley Ltd., identifying any interest to be carried forward. 
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3a
Taxation of cross border activities
​​In a Tax Master Class, one of the facilitators noted that “International tax relations are shaped by frameworks intended to balance domestic revenue needs with trade facilitation”.  
With reference to the above statement: 
 
(i) Assess the effectiveness of Advance Pricing Agreements (APAs) in providing tax certainty for cross-border transactions involving related persons in Kenya. 
 
(ii) Evaluate TWO anti-avoidance measures a government might deploy to counter the erosion of the tax base caused by entities routing transactions through Tax Havens. 
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3b
Limited companies
​ ​​Valley Petroleum Ltd. is a petroleum contractor involved in exploration and development in Kenya. The following
is the financial report for the year ended 31 December 2025:

Income:
• Sales of crude oil 1.8 million barrels at USD 78 per barrel (1 USD = Sh.132)
• Sale of natural gas Sh.540 million
• Gain on sale of exploration data Sh.115 million.
Expenditures:
• Exploration expenditure Sh.1.4 billion
• Development expenditure (Production commenced 1 April 2025) Sh.4.2 billion
• Decommissioning provision Sh.180 million
• Operating expenses Sh.620 million
• Royalties Sh.210 million
• Interest on non-resident parent loan Sh.125 million.

Additional information:
  1. Actual transfer to the Decommissioning escrow account was Sh.110 million.
  2. Operating expenses included a Sh.25 million penalty for violation of environmental regulations.
  3. On 1 March 2025, the parent company disposed of 30% of its stake in the contractor. Kenyan assets derive 80% of their value from immovable property.
  4. The contractor incurred Sh.45 million on the construction of a public school and a dispensary as part of social infrastructure.
  5. Operating expenses include Sh.60 million paid to a non-resident subcontractor for specialised technical support. Withholding tax at the rate of 10% was deducted but not remitted.
  6. The sale of natural gas is subject to a 60% cost recovery limit under the Ninth Schedule to the Income Tax Act.
  7. The contractor entered a farm-out agreement where a third party undertook Sh.200 million of exploration work for a 15% interest.
  8. The contractor seeks to set off a carried-forward exploration loss of Sh.320 million from a different contract area.

Required:
(i)  Prepare a statement showing the adjusted taxable profit or loss for Valley Petroleum Ltd. for the year ended 31 December 2025.

(ii) Determine the corporate tax payable if any, citing the applicable rate for resident petroleum companies.  
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4a
Tax planning Value added tax administration
​ ​​Discuss TWO tax planning avenues available to an importer of industrial machinery to legally minimise the impact of Value Added Tax and Customs Duty, citing the use of a Certificate of Origin.
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4b
Value added tax administration
​​Evaluate the procedural requirements and statutory timelines for a registered person to lodge a claim for a refund of excess input tax arising from making zero-rated supplies.
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4c
Value added tax administration
​ ​ ​​  Uzuli Manufacturers Ltd. is registered for Value Added Tax (VAT) and deals in standard-rated, zero-rated and exempt supplies. The following transactions occurred in the month of March 2026:

Purchases:
• Raw materials for taxable goods: Sh.29 million.
• Raw materials for exempt goods: Sh.11.6 million.
• New delivery truck: Sh.14.5 million.
• Saloon car for Managing Director (3,000cc): Sh.8.7 million.
• Fuel for distribution vans: Sh.2.32 million.
• Imported specialised software (Reverse charge): Sh.6.4 million.
• Stationery and electricity (Mixed-use): Sh.1.45 million.
• Specialised packaging materials for export tea: Sh.2.1 million.
• Passenger van (14-seater) for staff commuting: Sh.3.48 million.
• Professional training fees for e-TIMS integration: Sh.232,000.

Sales:
• Taxable supplies at standard rate: Sh.58 million.
• Export sales to EAC Partner States: Sh.18 million.
• Exempt supplies: Sh.14 million.
• Blended and packaged tea for local consumption: Sh.4.8 million.

Additional information:
1. Input tax on mixed-use items is apportioned as per the formula in Section 17(6) of the VAT Act.
2. A credit note of Sh.1.16 million was issued for standard-rated goods returned.
3. Input tax was disallowed on a raw material import valued at Sh.5 million due to a missing Certificate of Origin.
4. Insurance compensation of Sh.2.4 million was received for taxable raw materials stolen in transit.
5. Disposed of a warehouse forklift for Sh.3.5 million, originally a zero-rated supply for a specific project. This is now deemed an inconsistent use under Section 66A of the VAT Act.
6. Input tax claim of Sh.928,000 for maintenance was rejected due to a non-e-TIMS compliant manual invoice.
7. A customer declared legally insolvent on 15 March 2026 owes Sh.1.5 million for supplies made in January 2024.
8. During the month, the company supplied goods to a designated Withholding VAT Agent who withheld tax of Sh.450,000.
9. The tea blending and packaging project was approved by the Commissioner in writing as qualifying for zero rating.
10. A reverse charge payment of Sh.1.8 million was made for advertising services provided through a digital marketplace.
11. Hotel and catering expenses of Sh.232,000 were incurred for the regional sales team outside their usual place of work.
12. Management intends to claim input tax of Sh.750,000 on a consignment imported in August 2025.
13. Processed goods worth Sh.1.8 million were supplied to the Kenya Defence Forces Welfare Services.
14. The passenger van (14-seater) above acquired for staff commuting was confirmed by the logbook to have a tare weight of 2,200 kilograms and a load-carrying capacity exceeding 2 tonnes.
Transactions are inclusive of VAT at the rate of 16% where applicable.

Required:
Compute the VAT paid by or refundable to Uzuli Manufacturers Ltd., for the month of March 2026. 
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5a
Professional practice in taxation
​​As a senior tax consultant, you have been engaged by a Multinational Corporation to conduct a Tax Health Check, advising on why they need to conduct tax health check in addition to statutory financial audit. 

With reference to the above statement, Contrast TWO objectives of a “Tax Health Check” with that of a “statutory financial audit” as per professional tax practice standards.
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5b
Tax investigations
​​Under Section 89 of the Tax Procedures Act, the Cabinet Secretary may, on recommendation of the Commissioner, waive penalties and interest under specific circumstances related to electronic tax systems. 

In relation to the above statement, explain TWO circumstances under which a taxpayer may qualify for a waiver of penalties or interest arising from the use of an electronic tax system.
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5c
​ ​ ​​Benard Kiprotich has been under an in-depth tax investigation covering his personal and business affairs. The Revenue Authority conducted a wealth reconciliation for the years ended 31 December 2024 and 31 December 2025:

Item31 December 202331 December 202431 December 2025
Sh."000"Sh."000"Sh."000"
Residential villa (at cost)45,00045,00085,000
Bank balance (Local)7,200
(4,100)10,800
Offshore portfolio12,00018,50025,000
Motor vehicles18,00034,50034,500
Business inventory11,60014,8009,400
Mortgage loan(22,000)(19,500)(40,000)

Additional information:
  1. Benard’s living expenses amounted to Sh.400,000 per month in year 2024; Sh.600,000 per month in year 2025.
  2. During year 2025, Benard Kiprotich paid Sh.4.2 million in school fees for his children at a premium international school and Sh.1.5 million in annual subscriptions to exclusive golf and social clubs.
  3. In June 2025, he received a cash gift of Sh.15 million from his non-resident father.
  4. Investigation revealed unexplained deposits totaling Sh. 8.4 million in a joint bank account in year 2024.
  5. Benard Kiprotich owns a commercial mall that generated a net rental income of Sh.12.6 million in year 2025,
  6. which was excluded from his returns. In year 2024, he sold a piece of land for Sh.20 million (cost Sh.12 million).
  7. Reported business profits for tax purposes for the year 2024 and 2025 were Sh.8.4 million and Sh.10.2 million respectively.
  8. Benard Kiprotich received dividends of Sh.3 million from a foreign company located in a preferential tax regime.
  9. Benard Kiprotich paid Sh.1.8 million as mortgage interest for the residential villa; he also paid Sh.900,000 for a life insurance policy.
  10. During the year 2024, he received Sh.5 million from the settlement of a civil case involving a motor vehicle accident.
  11. Investigation found that Benard Kiprotich maintains a digital betting wallet, which showed withdrawals of Sh.2.1 million in year 2025; excise duty of 12.5% was deducted at source.
Required:
(i)   Determine for Benard Kiprotich the undeclared income for the years ended 31 December 2024 and 31 December 2025 using the wealth reconciliation method.

(ii)  Advise Benard Kiprotich on whether he could benefit on remission of penalties and interest if he applies under the tax amnesty on penalties, interest and fines as provided under the Tax Procedures (Amendment) Act, 2024, for any tax or interest that could arise from the tax investigation for the year 2024 and year 2025.
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