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Techsavana Company Limited v Commissioner of Domestic Taxes (Appeal 655 of 2021) [2023] KETAT 331 (KLR) (2 June 2023) (Judgment)

[2023] KETAT 331 (KLR) Tax Appeals Tribunal
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Court
Tax Appeals Tribunal
Case number
331
Citation
[2023] KETAT 331 (KLR)
Decided
2 June 2023
AI Summary Beta Machine-generated — may contain errors. Not legal advice.
TypeTax AppealPostureAppeal from a decision of the Commissioner of Domestic TaxesCoramRoland
Holding

The Tribunal held that the payments made by the Appellant to its outsourced developers were disbursements and not services subject to VAT.

Facts

Techsavana Company Limited was assessed VAT and withholding tax by the Commissioner of Domestic Taxes. The Appellant appealed the VAT assessment, and the Tribunal allowed the Appellant to amend its Memorandum of Appeal.

Issues

  1. Whether the Respondent erred in its assessment of VAT on the Appellant

Reasoning

The Tribunal determined that the outsourced developers were under the direct supervision of Safaricom, and the Appellant was merely facilitating the payments. Therefore, the amounts paid to the developers were disbursements and not services subject to VAT.

Outcome

Affirmed the objection decision of the Respondent and upheld the assessment of VAT.

Authorities cited

Legislation (1)
  • VAT Act
Experimental AI summary generated by a language model, not a lawyer. It may contain errors or omissions and must not be relied on for legal decisions — the full judgment below is the authoritative source.
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