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Coca Cola Central East and West Africa Limited vs. Commissioner of Domestic Taxes [2020] eKLR

Exported Services-Destination Principle

For exported services and service agreements involving both local and foreign entities, the destination principle is critical. Under this principle, a service rendered in Kenya is not necessarily treated as consumed in Kenya. Instead, the location of consumption is determined by the entity commissioning the service, rather than the entity providing the service or the location where the service is performed. This is particularly relevant for marketing and promotion services.

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