Menu

© Firu Africa, 2026. All rights reserved.

Ericsson (K) Limited vs Commissioner of Domestic Taxes 2016

Exported Services- Destination Principle

The Tribunal held that the marketing support services the Appellant provided were consumed outside Kenya by the two related non-resident entities, hence constituting exported services which were zero-rated for VAT purposes. The Tribunal relied on the destination principle under the OECD guidelines which provides that the jurisdiction where a customer is located has the taxing rights over internationally traded services.

Premium Plan

Built for Large Firms & Teams

Scale your operations with unlimited user access, dedicated support, and premium onboarding tailored for growing accounting and tax firms.

Starting From

KES 38,773

/ per month