Finance Act Analysis

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1.

Introduction
Once government priorities and expenditure targets for the financial year have been established through
the budget making process1, the government lays out a plan to collect revenue that will guarantee
provision of public services. This plan is the Finance Bill. The procedures outlined in the finance bill are
mainly efforts to streamline or increase efficiency in the collection of certain taxes, levies or service
charges. Consequently, the finance bill often simply makes amendments to other tax bills and money
laws2.
The Finance Bill, 2020 was tabled in the National Assembly on 6 th May, 2020. This followed the
constitutional interpretations issued by the Courts in 2018, that barred the government from collecting
taxes before the National Assembly had approved the relevant tax provisions. The proposed bill built up
on the changes introduced through the Tax Laws (Amendment) Act, 2020 (TLAA) that was assented on
25th April, 2020. It aimed to cushion Kenyans from the impact of the COVID-19. The bill was also
developed against the backdrop of a looming public debt crisis that has been the result of long-term
aggressive borrowing on expensive terms and the subsequent efforts of fiscal consolidation as well as a
forthcoming global recession.
The bill was passed on the 23rd June, 2020 following the National Assembly debate, and assented by the
President on 30th June, 2020 into the Finance Act.
We analyse the tax provisions on the basis provided above. The analysis is organised into three sections:
A Comparison between the Bill and the Act, an Analysis of the Finance Act, 2020, and the Conclusion
and Recommendations.

2. A Comparison Between the Finance Bill and the Finance Act


2.1. Income Tax Act (ITA), Cap 470
Section Finance Bill3 Finance Act4
6A: The Bill proposed to increase the upper The Act adopts the proposal. In addition,
Amendment threshold of Residential rental income it aligns the lower threshold from KSh
of Residential from KSh 10 million To KSh. 15 million 144,000 To current lower individual tax
Rental Income per annum. band of KSh 288,000 per annum.
Tax Effective 1 January, 2021.
12D; 34, Third Introduction of a Minimum Tax: a base The Act adopts the proposal.
Schedule: income tax payable by all companies Effective 1 January, 2021.
Introduction regardless of whether or not they make a
of Minimum profit at the rate of the tax is 1% of the
Tax gross turnover. The key elements of the
tax are as follows:
a) To be paid in instalments and due on
the 20th day of the 4th, 6th, 9th and
12th month of the year of income;
b) To be paid where the instalment tax
1
Learn about all things budget from IBP Kenya
https://www.internationalbudget.org/
2
How to Read and Analyse Your National and County Finance Bill
https://www.internationalbudget.org/publications/how-To-read-and-analyze-your-national-and-county-finance-bill/
3
http://kenyalaw.org/kl/fileadmin/pdfdownloads/bills/2020/PublicFinanceManagement_Amendment_Bill_2020.pdf
4
http://kenyalaw.org/kl/fileadmin/pdfdownloads/Acts/2020/TheFinanceAct_No.8of2020.pdf
payable is not higher than the
minimum tax.
Section Finance Bill Finance Act
c) shall not apply to: income exempted
under the ITA; employment income;
residential rental income; income
subject To Turnover Tax; income
subject To Capital Gains Tax and
income of entities operating in the
extractive sectors.
12E: Introduction of DST at a rate of 1.5% of The Act adopts the proposal.
Introduction the gross transaction value payable by a Effective 1 January, 2021.
of Digital person whose income from services is
Service Tax derived from or accrues in Kenya
(DST) through a digital market place.
The Bill proposed DST to be an advance
tax, and that residents and non-residents
with a permanent establishment could
offset the digital tax paid against their
income tax payable for that year of
income.
The tax shall be due at the time of the
transfer of the payment for the service to
the service provider.
15(2): The following items to be deleted from The Act adopts the proposal save for
Deletion of the list of allowable deductions: capital expenditure on the construction
allowable a) any entrance fee or annual of a public school, road or any similar
expenses subscription paid during that year of kind of social infrastructure with the
income to a trade association; prior approval by the Minister.
b) capital expenditure on legal costs Effective 1 January, 2021.
and other incidental expenses
relating to the authorization and
issue of shares, debentures or similar
securities offered for purchase by the
general public;
c) capital expenditure on legal costs
and other incidental expenses, for the
purposes of listing on any securities
exchange operating in Kenya,
without raising additional capital;
d) capital expenditure incurred on
rating for the purposes of listing on
any securities exchange;
e) club subscriptions paid by an
employer on behalf of an employee;
f) capital expenditure on the
construction of a public school, road
or any similar kind of social
infrastructure with prior approval by
the Minister.
22C: To delete the following provisions: The Act adopts the proposal.
Deletion of a) deductibility of contributions made Effective 1 January, 2021.
Home to registered home savings plans;
Ownership
Section Finance Bill Finance Act
Savings Plan b) exemption of interest income earned
(HOSP) on funds deposited in a registered
home savings plan.
Part I, First To delete the following income tax The Act adopts the proposal with the
Schedule: exemptions: exemption on income of the National
Deletion of a) on the income of a registered home Social Security Fund provided that the
Income Tax ownership savings plan; fund complies with such conditions as
Exemptions b) on income of the National Social may be prescribed.
Security Fund provided that the fund Effective 30th June, 2020.
complies with such conditions as
may be prescribed;
c) on Income from employment paid in
the form of bonuses, overtime and
retirement benefits to employees
whose taxable employment income
before bonus and overtime
allowances does not exceed the
lowest tax band.

2.2. Value Added Tax, 2013

Section Finance Bill Finance Act


17: Introduction of an additional requirement The Act adopts the proposal.
Amendment of that the registered supplier has made a Effective 30 June, 2020.
to Claim of corresponding declaration of the output
Input Tax tax in their return
68(2A): No proposal in the Bill. The Act provides for transitional
Special provisions to allow projects currently
Operating under SOFA To continue enjoying the
Framework VAT exemptions on goods imported or
Arrangement purchased locally for the remaining
(SOFA) period of the agreement.
Effective 30 June, 2020.
Part I, Section 1. To reclassify the following The Act adopts proposals 1(a)-1(g); 1(n)
A, First supplies from exempt to standard rate: Effective 1 July, 2021.
Schedule: a) Helicopters of an unladen weight not
Amendments exceeding 2,000 kg; The Act adopts proposal 1(i), 1(k), 1(l).
to VAT b) Helicopters of an unladen weight Effective 30 June, 2020.
Exemptions exceeding 2,000 kg;
c) Aeroplanes and other aircraft, of an The Act adopts proposal 1(j)
unladen weight not exceeding 2,000 Effective 1 July, 2021
kg;
d) Other parts of aeroplanes and The Act adopts the proposal 1(m)
helicopters; Effective 30 June, 2020
e) Air combat simulators and parts
thereof; The Act adopts the proposal 2(a) and
f) Aircraft launching gear and parts 2(b)
thereof; deck-arrestor or similar gear Effective 30 June, 2020
and parts thereof;
g) Other ground flying trainers and Moreover, the Act reclassifies the supply
parts thereof of maize (corn) flour, cassava flour,
wheat
Section Finance Bill Finance Act
h) Materials, waste, residues and by or meslin flour and maize flour
products, whether or not in the form containing cassava flour is suspended
of pellets, and preparations of a kind from exemption for 6 months
used in animal feeding; Effective 30 June, 2020
i) Specialized equipment for the
development and generation of solar The Act also reclassifies the supply of
and wind energy; aluminium pilfer proof caps with EPE
j) Tractors other than road tractors for liner from exempt to standard rate
semi-trailers. Effective 30 June, 2020
k) Taxable goods purchased by
manufacturers or importers of clean
cooking stoves;
l) Stove’s, ranges, grates, cookers,
barbeques, braziers, gas-rings, plate
warmers and similar nonelectric
domestic appliances;
m) One personal motor vehicle,
excluding buses and minibuses of
seating capacity of more than eight
seats, imported by a public officer
returning from a posting in a Kenyan
mission abroad and another motor
vehicle by his spouse and which is
not exempted from Value Added Tax
n) Hiring, leasing and chartering of
helicopters

2. To reclassify the following


supplies from VAT To exempt:
a) Maize (corn) seeds; and
b) Ambulance services
Second To reclassify the following supplies from The Act adopts proposal (a)
Schedule: zero rated to the standard rate: Effective 1 July, 2021
Amendments a) Liquid petroleum gas including
Zero rate propane The Act adopts the proposal (b)
b) Inputs or raw materials for electric Effective 30 June, 2020
accumulators and separators
including lead battery separator rolls Further, the Act reclassifies the supply of
whether or not rectangular or square maize (corn) flour, cassava flour, wheat
supplied to manufacturers of or meslin flour and maize flour
automotive and solar batteries in containing cassava flour to zero rated for
Kenya a period of 6 months.
Effective 30 June 2020

2.3. Excise Duty Act, 2015


Section Finance Bill Finance Act
2: To expand the definition to include a The Act adopts the proposal
Amendment license for any activity in Kenya for Effective 1 January, 2021
of licence which the Commissioner, by notice in
definition the
Section Finance Bill Finance Act
Gazette, may impose a requirement for a
licence.
10: No proposal in the Bill The Act adopts the requirement that the
Amended Commissioner should seek an approval
provisions for from the Cabinet Secretary for the
Inflation National Treasury and Planning in order
Adjustment to adjust the specific rate of excise duty.
Effective 1 January, 2021
Paragraph 1, To expand the alcoholic beverages that The Act adopts the proposal for category
Part I: are chargeable to excise duty by reducing (a). However, it further reduced the
Amended the alcoholic strength threshold from ten threshold for category (b) from the
Excisable percent (10%) To eight percent (8%) for proposed 8% To 6%.
Goods the following categories: Effective 30 June, 2020
a) spirits of undenatured ethyl alcohol
spirits liqueurs and other spirituous
beverages; and
b) beer, cider, perry, mead, opaque beer
and mixtures of fermented beverages
with non-alcoholic beverages and
spirituous beverages
Paragraph 5, No proposal in the Bill. The Act deleted the excise duty on
Part II: betting that had been introduced by the
Amended Finance Act, 2019 at a rate of 20%.
Excisable Effective 30 June, 2020
Services

2.4. Tax Procedures Act, 2015


Section Finance Bill Finance Act
37D: To introduce a confidential Voluntary The Act adopts the proposal
Introduction Disclosure Programme (VDP) where a Effective 1 January, 2021
of Voluntary taxpayer discloses tax liabilities
Tax previously undisclosed To the
Disclosure Commissioner To be granted relief of
Programme penalties and interest of the tax disclosed
(VDP) open for a period of 3 years effective 1st
January 2021. The programme will
operate as follows:
a) The disclosures eligible be for tax
periods of up to 5 years prior To 1st
July 2020;
b) successful applicants shall be
granted a remission of the interest
and penalty due on the tax liability as
follows:
 where the disclosure is made
and tax liability paid in the first year
of the programme, a 100% remission
of the interest and penalty;
 where the disclosure is made
and tax liability paid in the second
year of
 the programme, remission of
50%
Section Finance Bill Finance Act
of the interest and penalty; and
 where the disclosure is made
and tax liability paid final year of the
programme, remission of 25% of the
interest and penalty.
c) A taxpayer will not be eligible for
VDP where the taxpayer: -
 is under audit, investigation or
is a party to ongoing litigation in
respect of the tax liability or any
matter relating to the tax liability; or
has been notified of a pending audit or
investigation by the Commissioner
42B: To empower the Commissioner To The Act adopts the proposal.
Introduction appoint an agent for the purposes of Effective 1 January, 2021
of Digital Tax collection and remittance of the Digital
Agents Service Tax (DST).

2.5. Miscellaneous Fees and Levies Act, 2016


Section Finance Bill Finance Act
7(3): To amend the IDF chargeable on goods The Act adopts the proposal
Amendment imported under the East African Effective 30 June, 2020
of the EAC Community Duty Remission Scheme
Remission from a specific rate of KSh. 10 thousand
Scheme to an ad valorem rate of 1.5% of the
Import Customs value.
Declaration
Fee (IDF)
9A: To charge an additional duty of 2.5% of The Act adopts the proposal
Additional customs value in respect of goods Effective 30 June, 2020
duty on entered for home use from an Export
Export Processing Zone enterprise over and
Processing above the import duties under the
Zones Miscellaneous Fees & Levies Act.
Part A, The Bill proposed: The Act adopts the proposal (a)
Second a) To amend the exemption from (IDF) Effective 1 January, 2021
Schedule: for aircraft, to now exclude those
Amended IDF with an unladen weight not The Act adopts the proposal (b) and (c)
Exemptions exceeding 2,000kg and helicopters of Effective 30 June, 2020
heading 8802.11.00 and 8802.12.00.
b) To delete the exemption from IDF The Act adjusts the proposal (d) To
granted at the discretion of the exempt only equipment, machinery and
Cabinet Secretary for Treasury motor vehicles for the official use by the
where the Cabinet Secretary Kenya Defence Forces and National
determines it is in the public interest, Police from IDF and not all supplies as
or to promote investments on project proposed.
values of KES 200 million or more. Effective 30 June, 2020

Section Finance Bill Finance Act


c) To delete the exemption of goods
imported for implementation of
projects under a special operating
framework arrangement with the
Government from IDF
d) To exempt all goods, including
materials supplies, equipment,
machinery and motor vehicles for the
official use by the Kenya Defence
Forces and National Police from IDF

Part B, 1. To delete the RDL exemptions The Act adopts the proposal but adjusts
Second on any other goods as the Cabinet it further to exempt only equipment,
schedule: Secretary may determine are in public machinery and motor vehicles for the
Amended interest, or to promote investments official use by the Kenya Defence Forces
Railway which value shall not be less than KSh. and National Police from IDF and not all
Development 200 Million. supplies as proposed.
Levy (RDL) 2. To exempt: Effective 30 June, 2020
a) from the RDL the importation or
purchase of currency notes and coins
imported by the Central Bank of
Kenya
b) all goods, including materials
supplies, equipment, machinery and
motor vehicles for the official use by
the Kenya Defence Forces and
National Police from RDL.

2.6. Tax Appeals Tribunal Act, 2013


Section Finance Bill Finance Act
13: To restrict tax litigants to not only the The Act adopts the proposal
Appeal for grounds stated in the appeal but also to Effective 30 June, 2020
Procedures the documents relating to the objection
decision.

2.7. The Kenya Revenue Authority Act, 1995 (the KRA Act)
Section Finance Bill Finance Act
5(2A): To empower KRA to establish an The Act adopts the proposal
Introduction institution to provide capacity building Effective 30 June, 2020
of Capacity and training for the better carrying out of
Building and its functions
Training
Functions
16(1) (ba): To allow KRA to collect a commission The Act adopts the proposal
Introduction not exceeding 2% for collections on Effective 30 June, 2020
of Agency behalf of a county government or
Fees government agency.

Section Finance Bill Finance Act


20A: To propose that a legal action against the The Act adopts the proposal
Limitations of KRA shall not be instituted unless – Effective 30 June, 2020
Actions  it is commenced within 36 months
after the act, neglect or default
complained of; and
 in the case of continuing injury or
damage, within six months after the
cessation of the act; and
 at least one month written notice
specifying the particulars of the
claim, intention to commence the
action or legal proceeding has been
served upon the Commissioner
General.

2.8. Insolvency Act, 2015


Section Finance B Finance Act
37, Second to provide that all amounts held on The Act adopts the proposal
Schedule: behalf of KRA by banks appointed as Effective 30 June, 2020
1. Amendmen agents for revenue banking services,
t to the shall, at the point of receivership or
Insolvency liquidation of the bank, rank among the
Act preferential claims just like other
statutory obligations owed to the
government.
3. Analysis of The Finance Act, 2020
3.1. Residential Rental Income (RRI) Tax
The residential rental income tax was introduced in Finance Act 2016 as a measure to bring rental income
into the tax net and proved to be a simpler mode of compliance. Landlords with residential rental income
that does not qualify for RRI are required to maintain books of account and compute the profit which is
subject to income tax, which can prove cumbersome to landlords. Therefore, the increased range is a
welcomed move as it provides for more landlords to qualify for RRI especially in light of the COVID-19
pandemic.

3.2. Minimum Tax


The introduction of a minimum tax borrows from anti-tax avoidance provisions in countries like Canada,
India, Nigeria, Benin, Cameroon, Chad, Senegal and Tanzania, and appears to target businesses that are
not paying instalment tax (i.e. Businesses that are making losses. The tax may adversely impact loss
making businesses as there will be an additional cost now that they are required to pay the minimum tax.
Further, the provision is expected to have far reaching effects given the negative impacts of the COVID-
19 pandemic.

3.3. Digital Service Tax (DST)


The new tax follows the introduction of tax on a digital market place by the Finance Act, 2019. The new
tax is aimed at bringing into the tax net, non-resident companies that provide digital services to
consumers in Kenya who have traditionally not been taxable as their nature of business does not require
them to have a physical presence in Kenya. The Finance Act, 2020 provides more clarity on how the tax
will be implemented. Further, the Act also amends the Tax Procedures Act, 2015 to give powers to the
KRA to appoint agents for purposes of collection and remittance of DST which will ease collection of the
tax, However, there are still a number of unclear issues owing to the lack of a clear framework to
administer the tax nationally and internationally. The Digital Marketplace. The CS for National Treasury
and Planning is yet to develop the regulations while the OECD have not reached a consensus for the basis
for taxation of digital services.

3.4. Registered Home Ownership Savings (HOSP)


The Finance Act, 2020 has repealed the HOSP provisions in the ITA which means that there will be no
tax deduction allowed in respect to contributions made to a registered HOSP. This is because the
Parliamentary Finance Committee on the Finance Bill, 2020 cited that the HOSP regime, which was
started in 1995, was no longer effective as there has been low uptake. Additionally, the Committee also
stated that there are already in place various affordable housing initiatives including the Boma Yangu
affordable housing programme and the establishment of the Kenya Mortgage Refinance Company
(KMRC). Nevertheless, the repeal reverses attempts to encourage Kenyan taxpayers to save for
homeownership especially first time home owners.

3.5. Provisions for Input Tax


The KRA has been pursuing recipients of goods and services using the Value Added Automated System
(VAA). The amendments in the Finance Act, 2020 effectively legitimizes the VAA programme, whereby
taxpayers are being asked to provide reconciliations to support inconsistencies where their suppliers do
not declare the invoices issued to them in their returns However, the provision to disallow claims where
the supplier has not declared the supply is regressive as the recipient cannot be held responsible for the
supplier not having declared the supply, provided all the required documentation is in place. The
responsibility to charge, account for and pay VAT should lie lies with the supplier.
3.6. Reclassification of Supplies
The VAT changes set out in the Act effect systematic removal of tax exemptions so as to give rise to a tax
policy that limits VAT exemptions to only essential supplies as well as increase revenues collected.
However, some the tax provisions in the Act retrogrades some of the efforts made for environmental
conservation: reclassification of LPG and specialised equipment for wind and solar energy. Nonetheless,
the addition of maize seeds and ambulance services to the exempt schedule is a positive step given the
crisis currently facing the country.

3.7. Excisable Goods and Services


The Finance Act, 2020 tries to increase collectable revenue from alcoholic through excise duty by
widening the range of beverages that are subject to the tax. Meanwhile, it deletes the provisions for excise
duty on betting services. The Excise tax on betting services was introduced in the 2019 and led to the exit
from the Kenyan market of big betting firms, and over 600 jobs had been estimated to have been lost by
the closure of local betting firms. In addition, the excise duty tax had resulted in punters staking with
foreign betting firms that are not subject to the excise duty tax. However, proponents of imposing the sin
tax due to the effects that betting has on the youth in Kenya may consider this a setback.

3.8. Voluntary Tax Disclosure Programme


The introduction of voluntary tax disclosure programme (VDP) is meant to boost tax compliance at a time
when the KRA is struggling to hit revenue targets It represents the government’s attempt to encourage tax
payers to come forth and declare past tax liabilities in exchange for amnesty from prosecution and, in this
instance, remission from penalties and interests. With many businesses struggling due to the current
pandemic, engaging with KRA on the voluntary disclosure may come in handy to boost compliance.

3.9. Import Declaration Fee on Goods Imported under Duty Remission Scheme
The change of the duty remission scheme from a flat rate to an ad-valorem rate seem to be an attempt to
protect local industries through harmonizing the treatment of manufacturers under duty remission scheme
with manufacturers not in the scheme who pay IDF on an ad-valorem basis. Nonetheless, this measure is
likely to make intra East Africa trade more expensive.

3.10. Import Duty for EPZ


The Finance Act, 2020 introduces an additional 2.5% duty of the payable customs value to further boost
the primary objective of the EPZ model which is to export the commodities outside the EAC region while
discouraging local consumption of the same. The increase of the duty may have implications on the cost
of goods purchased from an EPZ and a decline on demand on goods manufactured from EPZs.

3.11. Exemptions from IDF and RDL


The amendments brought in by the Finance Act, 2020 in regard to IDF and RDL serve to streamline the
government strategy to increase collectable revenue and eliminate tax base erosion by reducing the
exemptions granted to foreign/private investors. Moreover, it also imposes the National Treasury’s new
policy to prioritise essential items for exemptions. This is appreciated as it speaks to the efforts of having
the ‘kawaida mwananchi’ front and centre when developing policies.

3.12. Amendments to the KRA Act


The finance Act, 2020 amends the KRA Act, 1995 to afford for a capacity building and training
institution as well as a statutory framework for the collection of agency fees from county governments by
the KRA. It further provides time limitations for legal actions against the KRA to protect the KRA from a
multiplicity of suits by limiting the time within which a person can sue.
3.13. Insolvency Act
The amendment to the Insolvency Act by the Finance Act, 2020 follows changes introduced by the Tax
Laws (Amendment) Act, 2020 which empowered the KRA to appoint banks as revenue collection agents.
It will ensure that the monies held on behalf of KRA by a Bank as an agent are treated as a debt owing to
KRA hence prioritized and remitted to KRA regardless of the Bank being liquidated.

4. Conclusion and Recommendations


The Finance Act, 2020 reflects the government’s attempts to expand the tax base and increase collectable
revenue. It does so by mostly prioritising the kawaida mwanachi and as a result, the amendments of the
various tax laws will most likely have adverse effects on the business and investment environment in
Kenya, especially in sectors like aviation and energy. Whereas the policy speaks to the maximum efforts
to increase revenue efficiency, it does not fully consider the current context of the country as outlined in
the introduction. It would have been essential to take on the recommendations of the World Bank Policy
Recommendations during the COVID-19 pandemic 5 published in April, 2020 before developing the
Finance Bill draft.
We therefore make the following recommendations:
1. The development of the Finance Bill, 2020 did not keep to the stipulated timelines as the bill was
tabled on the 6th of May instead of the stipulated 30th of April by the Budget Calendar. It is important
to ensure timely tabling of the bill as it would allow for effective participation by relevant
stakeholders and the public.
2. During the COVID-19 pandemic, it is important to safeguard jobs and firms against the increased
uncertainty brought about by the falling demands and revenues, reduced input supply, and tightening
credit conditions. The provisions against the Minimum tax and HOSP, among others, seem to be
retrogressive at this time. We recommend that the government consider being flexible to businesses
so as to cushion the impacts of the pandemic.
3. In regards to the DST, we urge the CS of National Treasury and Planning to take up full initiative in
publishing the regulations for the tax so as to streamline the provisions around the tax before they
start collecting it. Further, we ask that the regulations will be flexible to the international framework
currently in development.
4. The provisions for Input Tax that uphold the VAA programme is questionable following the recent
decision of the Tax Appeals Tribunal (TAT) that held that the KRA cannot introduce additional
criteria which are not founded in law as a basis for denying an input tax claim by a taxpayer. We
recommend that the provision is reconsidered to ensure that the responsibility to charge, account for
and pay VAT should lie with the supplier.
5. The provisions for the reclassification of VAT and repeal of the excise duty on betting services are
retrogressive of some of the milestones that ensure the well-being of the public. It is important that
the tax laws and policies developed consider the control measures put in place to safe guard the well-
being of Kenyan Citizens.

5
Kenya Economic Update, April 2020 https://openknowledge.worldbank.org/handle/10986/33673
i
References
1. Finance Bill, 2020 http://www.parliament.go.ke/sites/default/files/2020-05/Finance%20Bill%2C
%202020_compressed.pdf
2. Finance Act, 2020
http://kenyalaw.org/kl/fileadmin/pdfdownloads/Acts/2020/TheFinanceAct_No.8of2020.pdf
3. Finance Act, 2020 A KPMG Analysis
https://home.kpmg/content/dam/kpmg/ke/pdf/tax/Finance_Act_11_07_2020.pdf
4. Finance Act Analysis, 2020 https://taxwise-consulting.com/wp-content/uploads/2020/07/finance-act-
2020-kenya-analysis.pdf
5. Highlights of Amendments Under the Finance Act, 2020
https://www.kra.go.ke/images/publications/HIGHLIGHTS-OF-AMENDMENTS-UNDER-THE-
FINANCE-ACT-2020-b-1.pdf
6. AVERTING A CRISIS: ANALYSIS OF THE FINANCE ACT, 2020
https://reaction.bowman.co.za/rs/emsdocuments/Kenya%20Finance%20Act%202020%20Analysis.pdf

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