We deliver precise, commercially focused tax support across advisory, compliance, and planning. From structuring transactions to managing ongoing obligations, we ensure your tax position is both efficient and defensible. Our approach combines technical depth with practical execution—so you can operate with certainty in an increasingly complex tax environment.
Tarra’s Specialized TP Lawyers assist our clients in establishing and managing transfer pricing policies to ensure compliance with local and international regulations. This involves setting appropriate pricing for intra-group transactions, conducting benchmarking studies, and preparing documentation to substantiate pricing decisions.
Tarra’s Specialized TP Lawyers provide strategic tax planning to optimise our clients’ tax positions while ensuring compliance with local and international tax laws. This includes advice on repatriation of profits, tax-efficient financing structures, and the use of tax treaties to reduce double taxation.
Tarra supports our clients to navigate complex international tax reporting requirements. Our Specialized TP Lawyers ensure accurate and timely submission of various tax forms and reports, including Country-by-Country Reporting (CbCR) and Master File and Local File documentation.
Tarra’s Specialized TP Lawyers offer advice on cross-border financing structures, including thin capitalization rules, interest deduction limitations, and withholding tax optimization
Tarra keeps clients updated on international tax developments, including BEPS recommendations, and help them adapt to changing global tax rules.
Tarra advises on available research and development (R&D) tax incentives and credits in different African countries, helping our clients maximise benefits from innovation-related tax incentives
Tarra’s Specialized TP Lawyers conduct PE analyses to determine whether a client’s activities in foreign jurisdictions create a taxable presence, ensuring compliance with PE rules and mitigating tax risks.
We provide training and workshops to clients’ finance and tax teams to enhance their understanding of transfer pricing documentation requirements and compliance best practices.
In case of transfer pricing disputes with tax authorities, Tarra’s Specialized TP Lawyers represent clients during tax audits, negotiations, and appeals. They also assist in resolving disputes through Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) under tax treaties.
Tax litigation typically begins when a taxpayer disputes a decision or assessment made by the revenue authorities. This may involve disagreements over tax liability, tax assessments, penalties, interest, or tax refunds. The dispute may arise during a tax audit or as a result of differing interpretations of tax laws and regulations.
Before filing a case in court, taxpayers are usually required to engage in administrative procedures. This involves formally objecting to the revenue authorities’ decision and seeking an internal review. This step is crucial, as it provides an opportunity for resolution without resorting to litigation.
If the administrative review does not lead to a satisfactory resolution, the taxpayer can proceed to file a case in the Tax Appeals Tribunal and thereafter on appeal to the High Court
Once a case is filed, both parties prepare their arguments and evidence. Tarra tax lawyers play a crucial role in gathering relevant documents, witness statements, and expert opinions. The taxpayer must demonstrate that the tax authorities’ assessment or decision is excessive, incorrect or unjustified.
Tax litigation cases may involve hearings, submissions, and examinations under oath. The taxpayer and the tax authorities present their arguments before the Tax Appeals Tribunal or High Court. The process can be protracted and may involve several appearances and submissions
If either party is dissatisfied with the decision of the Tax Appeals Tribunal, they can further appeal to the High Court and, in some cases, the Court of Appeal or the Supreme Court of Kenya. The appeals process can extend the duration of the litigation significantly
At any stage of the litigation, the parties may explore the possibility of a settlement through negotiation or alternative dispute resolution methods, such as mediation. Settlements can be a practical way to resolve disputes while avoiding the costs and uncertainties of prolonged litigation
Ultimately, the tribunal or court issues a judgement. If the judgement favours the taxpayer, it may result in a reduction in tax liability, the removal of penalties, or the refund of overpaid taxes. Conversely, if the judgement favours the tax authorities, the taxpayer may be required to pay the assessed taxes, penalties, and interest.
After a judgement is issued, the taxpayer is obligated to comply with the court’s decision. This may involve making payments, adjusting tax returns, or taking other necessary actions.
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