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Kenya’s Tax Appeals Tribunal (TAT) held that without proof of material nondisclosure or misinformation, the Kenya Revenue Authority (KRA) is bound by its own private ruling, which may not be arbitrarily revoked to the detriment of a taxpayer.
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The KRA issues private rulings under Section 65 of the Tax Procedures Act (TPA).
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Once issued, a KRA private ruling should be binding on all transactions (covered within the ruling) initiated in the period that the ruling is valid. If the ruling is revoked, the revocation should apply to subsequent transactions.
Source: EY
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