The Kenya Revenue Authority publishes a 30% corporate income-tax rate for resident companies and 37.5% for non-resident companies. General VAT is 16%. Capital gains tax is 15%. Official starting points include the KRA company taxation page, KRA VAT guidance and KRA capital gains page.

The structure model should cover corporate residence, permanent establishment, withholding, transfer pricing, interest limitation, VAT, payroll, customs, excise and treaty access. Digital businesses should consider rules for remote supplies, marketplaces and significant economic presence rather than assuming no local company means no Kenyan tax.

Register for the correct tax accounts before transactions begin. Classify supplies, determine the invoice and electronic tax invoice treatment, and clarify whether contract prices include or exclude VAT. Imported services and cross-border management, technology, financing and IP payments need withholding, VAT and transfer-pricing review.

Related-party pricing should reflect actual functions, assets and risks and be supported by agreements, deliverables and allocation methods. Treaty relief requires substantive eligibility and prescribed evidence. Customs value and income-tax transfer pricing are connected but not identical.

Finance controls should reconcile ledgers, invoices, payroll and customs to returns and maintain a filing calendar. Tax incentives and special regimes depend on detailed conditions; do not advertise or model an incentive without confirming the eligible entity, activity, location, approval and continuing compliance.