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Prime Bank Limited v Commissioner of Domestic Taxes (Appeal 073 of 2022) [2024] KETAT 95 (KLR) (2 February 2024) (Judgment)

[2024] KETAT 95 (KLR) Tax Appeals Tribunal
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Court
Tax Appeals Tribunal
Case number
95
Citation
[2024] KETAT 95 (KLR)
Decided
2 February 2024
AI Summary Beta Machine-generated — may contain errors. Not legal advice.
TypeTax AppealPostureAppeal from a notice of assessment and objection decisionCoramGrace Mukuha, E Komolo, T Vikiru, G Ogaga
Holding

The Tribunal held that interchange fees and merchant fees are financial services exempted from VAT under Paragraph 1 of Part II of the VAT Act 2013.

Facts

Prime Bank Limited filed tax declarations and VTDP applications in 2021 for tax periods 2017-2019. The Commissioner of Domestic Taxes issued a notice of assessment and subsequent assessment orders for additional VAT on merchant fees and interchange fees. The Appellant objected to these assessments.

Issues

  1. Whether the objection decision dated 9th December 2022 is proper in law.

Reasoning

The Tribunal considered the exemptions in Paragraph 1 of Part II of the VAT Act 2013 and cited the High Court's decision in Commissioner of Domestic Taxes v Bank of Africa Limited (Civil Appeal E127 of 2020) [2023] KEHC 1036 (KLR) for the interpretation of Paragraph 1(b).

Outcome

The Tribunal upheld the Appellant's appeal and set aside the objection decision.

Orders

  • Set aside the objection decision dated 9th December 2022

Authorities cited

Legislation (2)
  • VAT Act 2013
  • KRA Act
Cases cited (1)
  • Commissioner of Domestic Taxes v Bank of Africa Limited (Civil Appeal E127 of 2020) [2023] KEHC 1036 (KLR)
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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