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Kenya High Court rules technical fees are not taxable in source country unless recipient has PE in source country under Kenya-France DTA

|Tax Alerts, Legislation & Policy, Treaties|France, Kenya
France, Kenya
  • Kenya's High Court has upheld the decision of the Tax Appeals Tribunal that technical fees under the Kenya-France DTA are taxable in the country of residence of the recipient unless where they have permanent establishment in the other state.
  • The Kenya-France DTA is modeled after both the OECD and UN Model Tax Conventions.
 

Executive summary

The High Court has upheld the position held by the Tax Appeals Tribunal (TAT) on the taxation of technical fees under the Kenya-France Double Tax Agreement…

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