Cross-Border Tax Advisory & Transfer Pricing
International tax compliance and cross-border transactions, handled
Cross-border business raises hard tax questions: transfer pricing, withholding tax, double taxation and permanent establishment risk. KRA scrutiny of related-party transactions has intensified, and weak documentation is costly: adjustments, assessments and prolonged disputes. We help you structure international transactions efficiently and compliantly: arm's-length pricing, transfer pricing policies and documentation, DTA relief and PE assessments, whether you are a multinational operating in Kenya, a Kenyan business expanding abroad or a foreign investor entering the market.
- Registered KRA Tax Agent
- 15 years of experience
- OECD-aligned transfer pricing documentation
What we can help you with
The full scope of this service. If what you need isn't listed, ask. It may sit in a neighbouring service.
- Cross-border tax planning and advisory
- Transfer pricing advisory and policy development
- Preparation and review of transfer pricing documentation
- Related-party transaction analysis
- Arm's length pricing assessments
- Double Taxation Agreement (DTA) advisory
- Withholding tax advisory for international transactions
- Permanent Establishment (PE) risk assessment
- International business structuring
- Tax-efficient investment structuring
- Cross-border financing advisory
- International service agreement reviews
- Tax implications of mergers, acquisitions and group reorganizations
- Foreign investment tax advisory
- KRA transfer pricing audits and dispute support
- Advance tax planning for multinational operations
What your business gains
Comply with Kenya's international tax and transfer pricing regulations.
Lower the risk of transfer pricing adjustments, penalties and disputes, backed by robust documentation.
Structure international transactions in a commercially sound, tax-efficient manner.
Apply Double Taxation Agreements correctly to reduce double taxation where treaty relief is available.
Catch permanent establishment and cross-border risks before they become liabilities.
How we work
- 01
Understanding your international activities
We map your structure, ownership, jurisdictions, related-party relationships and financing arrangements to identify exposures and planning opportunities.
- 02
Tax risk assessment and technical review
We review cross-border transactions, intercompany agreements, pricing methodologies and documentation against Kenyan legislation, TP rules and applicable DTAs.
- 03
Advisory and implementation
We design transfer pricing policies, prepare documentation, review contracts and restructure transactions where appropriate, keeping everything compliant and commercially aligned.
- 04
Ongoing compliance and dispute support
We keep documentation current, monitor legislative developments and represent you during KRA transfer pricing reviews, audits and disputes.
Frequently asked questions
Which businesses require transfer pricing documentation?
Businesses transacting with related parties, whether locally or across borders, may be required to maintain transfer pricing documentation under Kenyan regulations. We assess your circumstances and advise on your documentation obligations.
What is the arm's length principle?
It requires transactions between related parties to be conducted on terms and pricing comparable to those that would apply between independent parties in similar circumstances. It is the foundation of transfer pricing rules in Kenya and internationally.
Can you assist businesses investing in Kenya?
Yes. We advise foreign investors on tax-efficient investment structures, corporate tax obligations, withholding taxes, transfer pricing requirements, available treaty benefits and ongoing compliance in Kenya.
What are Double Taxation Agreements (DTAs), and how do they benefit businesses?
DTAs are treaties between countries that prevent the same income being taxed twice. Depending on the treaty, they may reduce withholding tax rates, allocate taxing rights between jurisdictions and provide certainty for cross-border investors. We advise on the availability and application of treaty benefits.
Can Altic Consult represent businesses during KRA transfer pricing audits?
Yes. We provide professional representation during KRA transfer pricing reviews and audits: reviewing documentation, preparing technical responses, analyzing methodologies and supporting you through dispute resolution.
Expand globally with confidence
Manage cross-border tax risk, strengthen transfer pricing compliance and build sustainable international operations.