WebAs per the Income Tax Act (ITA), thin capitalization in the Kenyan context is based on two issues: A. Control Company A, which is not resident in Kenya, either directly or indirectly, controls at least 25% or more of the voting … Web3 Jun 2024 · Unlike the prior year, the bill does not introduce new taxes. However the bill proposes significant changes that will indeed have a far reaching effect on multinational …

THE EFFECT ON RESTRICTION OF INTEREST EXPENSE (KENYA …

WebThin Cap Rules. The Bill also proposes that thin capitalization shall apply to the gross interest paid or payable to related persons and third parties in excess of 30% of EBITDA … WebThin capitalisation work involves applying the arm’s length principle to company borrowing and lending, taking into account all the terms and conditions and other factors affecting … clayton homes wind zone

INTM511015 - Thin capitalisation: practical guidance ... - GOV.UK

Web19 Sep 2024 · Thin capitalization arises where a company incorporated in Kenya is controlled by a non-resident person alone or together with four or fewer other persons … WebThin capitalisation rules determine how much of the interest paid on corporate debt is deductible for tax purposes. Such rules are of interest to private-equity firms , which use … Web28 Oct 2024 · Three broad practices have been suggested to tackle the issue of thin capitalisation. First, the fixed ratio rule, which limits the interest costs benchmarked as a percentage of earnings before interest, taxes, depreciation, and amortisation (Ebitda). This restricts an entity’s net interest deductions to a fixed percentage (say, between 10 to ... down shut down