How the Always-On Tax Health Check works

Expert advisory, enabled by proprietary technology. A precise explanation for CFOs, Heads of Legal, and Finance Directors.

From your data to a certified report.

Click each stage to expand the full detail. The pipeline runs from data submission to certified PDF delivery within 48 hours.

You submit your financial data through the ATT secure upload portal. The portal accepts all major ERP export formats. Your data is encrypted with AES-256 before it touches the ATT server and never leaves your engagement's isolated data environment.

Trial balance / general ledger
CSV, Excel, or ERP export. All accounts, all periods.
VAT returns & purchase register
iTax VAT-3 returns. Supplier invoice register.
Bank statements, all accounts
12 months minimum, full transaction narrative.
Payroll & PAYE schedules
Monthly payroll summary, P9 forms, car allowance register.

ATT's one-of-a-kind knowledge base, TAT and High Court decisions, KRA notices, Kenya statutes at section level, is loaded for this specific engagement. This database is not available anywhere else in Kenya. No case is ever invented. Every citation in the report was retrieved from this store.

Six independent AI agents run in parallel, VAT, CIT, PAYE, Withholding Tax, Transfer Pricing, and Customs. Each agent runs 20+ expert-authored checklist items against your submitted data, grounded exclusively in retrieved case law.

VAT Agent
20+ checks
CIT Agent
20+ checks
PAYE Agent
20+ checks
WHT Agent
20+ checks
TP Agent
20+ checks
Customs Agent
20+ checks

Every finding is reviewed by a named, qualified ATT tax professional before the report leaves ATT. The expert can accept, override, escalate, or suppress any AI-generated finding. The certified report carries a digital signature. The expert is professionally liable for the output.

Source law only. Signed by a named expert.

Grounded in source law

Every citation comes from the curated knowledge base of decided cases, statutes and KRA notices, no open-internet sources, no generic summaries, no opinion content.

Source law only · verified citations

Expert certification

Every finding is reviewed and signed by a named, qualified practitioner before it is released. Findings are issued as tax intelligence; a formal opinion is given separately under engagement.

Named practitioner · digital signature

Document security

AES-256 at rest, TLS 1.3 in transit, row-level client isolation, zero-data-retention on every AI call, and automatic purge 90 days after delivery.

AES-256 · TLS 1.3 · ZDR enforced

Grounded in a decided case, not a general principle.

Every ATT finding names the authority behind it: the case, the statute section, the notice. Your team can open the source and read it.

VATHigh risk

Your supplier's eTIMS failure is now your VAT liability. Input VAT is disallowed where the supplier cannot be verified, even where goods were delivered and paid for. Good faith is not a defence, and KRA cross-checks at the point of filing.

Legal basis: Gedi Boss Trading v CDT (TAT) · VAT Act, s.17(3) · KRA Public Notice

Transfer pricingContemporaneity

A KES 6.8 billion transfer-pricing assessment was defeated because the documentation was contemporaneous and specific to the entity's actual functions, assets and risks. Where a taxpayer's own TP policy mischaracterised its functions, the Commissioner's re-characterisation was upheld.

Legal basis: Wildlife Works Sanctuary v CLSBC (TAT, 2025) · ECP Kenya

ProcedureThe calendar

Appeals struck out for being 16 days late, months late, or for failing to attach the objection decision. And the mirror image: where the Commissioner misses the 60-day clock, the objection is deemed allowed by operation of law, a remedy only for the team that was tracking it.

Legal basis: Atta Kenya · Terrazzo · Kapiheri · Acer Petroleum · Atcost Structures

One knowledge base - refreshed daily. Every source that binds you.

Most finance teams rely on KRA notices, a audit firm newsletters, annual tax health checks and WhatsApp group forwards. None of these is indexed to decided law - and the newsletter withholds the analysis until you pay for an engagement. Africa Tax Terminal indexes 5,426+ legal documents spanning the full hierarchy of Kenyan tax authority, updated as new law is published.

01

The Constitution of Kenya

The top of the hierarchy - and the limit behind every "interests of justice" argument at the Tribunal and High Court.

Indexed
02

Decided tax cases - Tribunal to Supreme Court

The binding interpretation of the statutes: Tax Appeals Tribunal, High Court, Court of Appeal and Supreme Court, indexed as decisions are published.

Indexed & Tax Rules Synthesized
03

KRA public notices, practice notes & alerts

The revenue authority's interpretation - held in its proper place: persuasive, not binding to the taxpayer but valuable insight.

Indexed & Tax Rules Synthesized
04

East African Community legislation

Including the Customs Management Act that governs every import and tariff-classification dispute. Treats the EAC as a single customs territory.

Indexed & Tax Rules Synthesized
05

OECD guidance & Kenya's Double Tax Agreements

The international layer over every cross-border and transfer-pricing position. Relevant for every cross border transaction, regardless of materiality.

Indexed & Tax Rules Synthesized
06

Tarra Agility expert-certified checklists & curated cases

Including decisions not yet indexed on eKLR -structured by the practitioners who argue them. This is the judgement call that needs to be taken when the law is not clear. An experienced practitioner weighs in.

Indexed & Tax Rules Synthesized

The risk that matters to you is the risk in your sector.

A manufacturer's exposure on duty remission and tariff classification is not a bank's exposure on excise, and neither is an FMCG distributor's exposure on a long supplier list. ATT's analysis is worked sector by sector, so what reaches your team is the development that affects your business, not a general bulletin. And it reaches them where they already work.

WhatsApp, for the CFOMicrosoft TeamsSlack, for the finance teamEmail

When a KRA notice and the Tribunal disagree, your team backs the notice.

That instinct is the exposure. A notice is only the revenue authority's interpretation - a Tribunal or court decision can override it. Knowing which source wins is exactly the training a finance team doesn't have. Africa Tax Terminal reasons from the top of the hierarchy down, and surfaces the conflict when a notice can't survive the decided law above it.

This is binding law

01

The Constitution

Supreme
02

Statute, ITA · VAT Act · TPA · EACCMA

Binding
03

Case law, SC → CoA → HC → Tribunal

Binding
04

KRA notices & practice notes

Interpretation

Where your team looks first

How ATT resolves a conflict

The team's position

A KRA practice note interprets a provision in the direction of collection. Working from the notice, your team files the position.

The decided law

A Tribunal or court reads the same statute differently, and sits above the notice in the hierarchy.

ATT surfaces

The decision binds. ATT flags that the notice does not survive it, before the filing becomes an assessment.

Ask the knowledge base directly.

Between reports, your team can ask Africa Tax Terminal a question in plain English and get an answer drawn only from the knowledge base, the 5,426 indexed legal documents, nothing from the open internet, nothing invented. All source documents are available in raw form.

  • Answers are specific to your sector, not generic guidance. The case law, KRA Notices and Tax Statutes are available in raw form.
  • Every response carries clickable links to its sources: one click opens the actual case, statute section or KRA notice it rests on. Your finance team works from documentation it can open and cross-reference, not a black box.
  • Where a question turns on a genuinely uncertain area of law, it says so and routes you to a practitioner rather than forcing a false answer. The Tarra Agility tax expert supports the finance team to make a judgement call on the interpretation of a legal provision that does not fit squarely into the business circumstances.
  • Turn any answer into a drafted memo or client email in a click, and every consultation is saved to your projects for the team to pick up later.
The chat delivers grounded tax intelligence. Where a matter needs a formal opinion, that opinion is given separately by Tarra Agility Africa under engagement, signed, and carrying the professional responsibility that attaches to it.
ATT · Chat · Knowledge base only

Are management fees to our German parent fully deductible?

Not necessarily. Section 18(5) of the Income Tax Act restricts the deduction of management fees paid by a Kenyan permanent establishment to its head office, and this has been held to apply notwithstanding the double-tax agreement. The position turns on your specific structure.
Note: this is a fact-specific area, a Tarra Agility practitioner can confirm on your structure.