By Christine Kinage, Senior Associate - Tax
Delmonte Kenya Limited has challenged KRA’s transfer pricing adjustments arising from a 2019–2021 audit that resulted in a confirmed tax assessment of KES 4.96 billion.
The dispute centers on the characterization of the company’s functions, the transfer pricing method applied to related‑party sales to DMI GmbH, and the disallowance of various intercompany recharges and interest expenses.
Click on the link below to download the full judgement alert.
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