Income Tax Appeal E079 of 2024
Limitation of Benefits (LOB)
This article analyzes the Nairobi Bottlers Limited v KRA case (Income Tax Appeal E079 of 2024), focusing on the application of Limitation of Benefits (LOB) under the Kenya–South Africa Double Taxation Agreement. It explores how ownership tests, treaty interpretation, and domestic tax law affect eligibility for DTA relief and refund claims. The High Court ruling sets a precedent for multinational tax compliance and cross-border payments in Kenya.