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Corporation Tax

Income tax on company profits and gains. Comprehensive guide to corporate tax obligations, rates, deductions, and compliance requirements for businesses operating in Kenya.

Corporate Tax
30% / 37.5%
Annual Filing

What is Corporation Tax?

Understanding corporate income tax in Kenya

Corporation Tax is income tax charged on the profits of companies incorporated in Kenya or foreign companies with permanent establishments in Kenya. It applies to all forms of business income including trading profits, investment income, and capital gains, ensuring comprehensive taxation of corporate earnings.

Who Pays Corporation Tax?

All companies incorporated in Kenya, foreign companies with permanent establishments, partnerships with corporate partners, and trusts earning business income must pay corporation tax.

Filing Requirements

Annual returns must be filed within 6 months after year-end. Companies must also pay advance tax in quarterly installments and submit monthly PAYE returns for employees.

Tax Rates

Standard rate of 30% for resident companies and 37.5% for non-resident companies. Minimum tax of 1% of gross turnover applies when corporate tax is lower.

Compliance Benefits

Proper compliance enables access to government contracts, bank facilities, licensing, and protects against penalties while building credibility with stakeholders.

Company Types & Tax Rates

Different rates for different company categories

Resident Companies
Companies incorporated in Kenya or with central management and control in Kenya. Includes limited liability companies, partnerships with corporate partners.
30% Standard Rate
Non-Resident Companies
Foreign companies with permanent establishments in Kenya or deriving income from Kenyan sources. Higher rate reflects limited local presence.
37.5% Higher Rate
Branches of Foreign Companies
Kenyan branches of foreign companies subject to both corporation tax on profits and additional branch profits tax on repatriated profits.
37.5% + 15% BPT
Partnerships (Corporate Partner)
Partnerships where at least one partner is a company are subject to corporation tax on their share of partnership profits and gains.
30% / 37.5%
Trusts & Estates
Trusts earning business income, unit trusts, and estates of deceased persons carrying on business activities are subject to corporation tax.
30% Standard Rate
Special Economic Zones
Companies operating in Special Economic Zones may qualify for reduced tax rates and other incentives based on their activities and investments.
Various Incentives

Corporation Tax Rates 2024

Current rates and minimum tax provisions

Company CategoryCorporation Tax RateMinimum Tax RateAdditional Provisions
Resident Companies30%1% of Gross TurnoverStandard rate applies
Non-Resident Companies37.5%1.5% of Gross TurnoverHigher rate for foreign entities
Branch Profits (Additional)15%N/AOn repatriated profits after tax
Shipping Companies2%N/AOn gross freight earnings
Air Transport5%N/AOn gross receipts from Kenya

Minimum Tax Provisions

  • Minimum Tax: Payable when corporation tax is less than 1% of gross turnover
  • Exemptions: First year of operation, companies in tax loss position
  • Credit: Minimum tax paid can be offset against future corporation tax
  • Special Rates: Apply to specific industries like shipping and aviation

Allowable Deductions

Expenses that reduce taxable income

Operating Expenses
Rent, utilities, salaries, professional fees, and other expenses incurred wholly and exclusively for business purposes during the income year.
Operating
Depreciation Allowances
Capital allowances on qualifying assets: 37.5% on computers, 25% on general plant and machinery, 10% on industrial buildings, 2.5% on commercial buildings.
Capital
Interest on Borrowed Capital
Interest paid on money borrowed for business purposes, subject to thin capitalization rules limiting deductible interest to 30% of EBITDA.
Finance
Bad Debts
Debts written off as irrecoverable during the year, provided they were previously included in taxable income and reasonable efforts made to collect.
Trading
Employee Benefits
Salaries, PAYE, NSSF, NHIF contributions, gratuity, pension contributions, and other employment-related expenses for company employees.
Personnel
Professional Fees
Legal, accounting, consultancy, and other professional service fees incurred for business purposes, subject to proper documentation and business justification.
Professional

Corporation Tax Filing Process

Step-by-step compliance guide

1

Prepare Financial Statements

Prepare audited financial statements including profit & loss, balance sheet, cash flow statement, and notes. Ensure compliance with applicable accounting standards.

2

Calculate Taxable Income

Adjust accounting profit for tax purposes by adding back non-deductible expenses and deducting allowable expenses not in accounts.

3

Complete Tax Computation

Calculate corporation tax using applicable rates, determine minimum tax liability, and offset advance tax payments and withholding taxes.

4

File CT1 Return

Submit corporation tax return (CT1) via iTax portal within 6 months after year-end, attaching financial statements and supporting schedules.

5

Pay Outstanding Tax

Pay any balance of tax due after offsetting advance tax payments. Late payment attracts penalties and interest at prescribed rates.

6

Maintain Compliance

Keep proper books of account, pay advance tax quarterly, file monthly PAYE returns, and respond promptly to KRA inquiries.

Important Filing Deadlines
Corporation Tax Returns6 Months After Year-End
Advance Tax Q120th April
Advance Tax Q220th June
Advance Tax Q320th September
Advance Tax Q420th December
Monthly PAYE Returns9th of Following Month

Common Compliance Issues

Avoid these costly mistakes and penalties

Late Filing of Returns

Filing corporation tax returns after the 6-month deadline attracts penalties of 25% of tax due or KSh 20,000 (whichever is higher), plus 1% monthly interest.

Solution: Plan filing process early and engage qualified professionals to ensure timely compliance.

Inadequate Record Keeping

Poor documentation of expenses and transactions leads to disallowed deductions during audits and potential additional tax assessments.

Solution: Implement robust accounting systems and maintain supporting documents for all transactions.

Advance Tax Defaults

Failure to pay quarterly advance tax installments results in penalties and interest charges, increasing the overall tax burden significantly.

Solution: Set up quarterly payment schedules and base estimates on realistic profit projections.

Transfer Pricing Issues

Related party transactions not conducted at arm's length can trigger transfer pricing adjustments and substantial penalties.

Solution: Maintain proper transfer pricing documentation and ensure arm's length pricing for related party transactions.

Frequently Asked Questions

Common corporation tax questions answered

When is minimum tax applicable and how is it calculated?

Minimum tax applies when your corporation tax liability is less than 1% of gross turnover (1.5% for non-residents). It's calculated as 1% of gross turnover for the year. Companies in their first year of operation or in a tax loss position are exempt. Minimum tax paid can be offset against future corporation tax liabilities.

How do thin capitalization rules affect interest deductions?

Under thin capitalization rules, interest deductions are limited to 30% of EBITDA (Earnings Before Interest, Tax, Depreciation, and Amortization). This prevents excessive debt financing to reduce taxable income. Interest exceeding this limit is not deductible in the current year but can be carried forward to future years subject to the same limitation.

What are the advance tax payment requirements for companies?

Companies must pay advance tax in four equal quarterly installments by 20th April, 20th June, 20th September, and 20th December. The total advance tax should be 100% of the previous year's corporation tax or 110% if turnover exceeds KSh 1 billion. New companies estimate based on expected profits for the first year.

Can losses be carried forward and how long?

Tax losses can be carried forward indefinitely and offset against future profits from the same source. However, losses cannot be carried back to previous years. Investment losses can only be offset against investment income, while business losses can be offset against business income. Proper documentation of losses is essential for future claims.

What is branch profits tax and when does it apply?

Branch profits tax at 15% applies to after-tax profits of Kenyan branches of foreign companies when profits are repatriated to the head office. This is in addition to the 37.5% corporation tax on branch profits. The tax ensures that branch profits face similar taxation to dividend distributions by subsidiary companies.

How are capital allowances calculated for different assets?

Capital allowances vary by asset type: computers and software (37.5%), general plant and machinery (25%), motor vehicles (25%), furniture and fittings (10%), industrial buildings (10%), and commercial buildings (2.5%). Allowances are calculated on a reducing balance basis except for buildings which use straight-line method. Assets must be used for business purposes to qualify.