By Benadeta Mwaura - Reporter
Kenya, December 09 2025 - The Kenya Revenue Authority (KRA) has secured another major victory at the Tax Appeals Tribunal after the panel upheld a Sh346.2 million tax demand against ICT company Jo World Agencies Limited, ruling that the firm failed to provide documents necessary to challenge the assessment.
The decision, delivered on 9 December 2025, dismissed Jo World’s appeal and affirmed KRA’s multi-year audit covering 2017 to 2022, during which the agency analysed the company’s bank records and financial statements before issuing assessments across several tax heads, including corporation tax, PAYE, withholding tax, excise duty, and gaming and betting levies.
According to the Tribunal, Jo World did not submit invoices, contracts, receipts, exemption proof or any supporting documentation during the objection or appeal stages, making it impossible to verify the legitimacy of the company’s claims. Under Section 56 of the Tax Procedures Act, the burden of proving that an assessment is incorrect lies with the taxpayer.
“The appellant failed to discharge the burden of proof placed upon it by law. In the absence of supporting documents, the respondent’s assessment must stand,” the Tribunal held in its ruling.
KRA had relied on bank-deposit analysis and variance tests, tools increasingly used when companies fail to maintain proper accounting records, to reconstruct Jo World’s income. The Tribunal ruled that these methods were lawful, especially where taxpayers do not provide contrary evidence.
The ruling adds to a growing list of significant cases where tribunals have sided with the tax authority in disputes involving large assessments. Earlier this year, the Tribunal upheld a Sh681 million claim against MultiChoice Africa Holdings, ruling that the broadcaster had failed to justify its VAT offset requests.
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In another high-profile case, international communications firm Oxygen 8 East Africa lost an appeal worth Sh1.2 billion after the Tribunal found that it had filed an incomplete memorandum and failed to meet statutory deadlines, according to a statement by KRA.
The trend reflects a shift in Kenya’s tax enforcement landscape, with KRA increasingly leveraging audits, financial-flows analysis and scrutiny of bank statements to detect undeclared income, particularly among ICT, digital-service, and platform-based companies.
However, not all rulings have favoured the taxman. In November, the High Court blocked a KRA assessment against a local insurance company, terming the claim time-barred and therefore unlawful, signalling that tax actions must still meet strict procedural requirements.
The Jo World decision reinforces the legal expectation that businesses must maintain and produce complete accounting records when audited. For sectors such as ICT, where firms often handle multiple revenue streams, cross-border payments, and digital transactions, the ruling underscores rising compliance risks.
KRA is yet to comment on whether it will pursue enforcement action to collect the Sh346 million, while Jo World Agencies has not publicly indicated whether it will escalate the matter to the High Court.
