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Judgment – Tat No. 65 Of 2023 M-Kopa Llc (C/O M-Kopa Kenya Limited) Vs. Commissioner Of Domestic Taxes

Place of Effective Management (POEM)

“The POEM is thus where the company is actually managed. Put another way, it is where the key management and commercial decisions that are necessary for the conduct of the entity‘s business are in substance made. This definition is aligned and consistent with the ITA which has defined a resident in regard to corporate persons to mean the place where management and control of the affairs of the corporate body was exercised.”

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