Head of Tax and Legal

• Apr 2020 - Present

Senior Associate - Tax

• Jul 2019 - Apr 2020

I am a Senior Associate in Anjarwalla & Khanna's Tax Department. I am a specialist in indirect taxes, covering a wide range of industries in Kenya including banking, insurance, finance, agriculture, power, beverages and construction. I am also a leading expert in structuring, jurisdictional analysis and transfer pricing as well as setting up and performing tax due diligences in the context of corporate mergers and acquisitions. In addition, I routinely provide legal and tax support to multinational enterprises in disputes with the Kenya Revenue Authority, as well as supporting such entities during tax audits.

Principal Associate, Tax

• Jan 2017 - Jun 2019

Selected Assignments and Achievements:- Rainforest Farmlands Kenya Limited: I was the team leader for this project. This assignment involved negotiation with the KRA over a tax assessment of KES 800 million in conjunction with Deloitte and Touche. We were able to negotiate the tax payable to KES 25 million and appealing against the sum of KES 164million.- Google Kenya Limited: Acted as the team leader in this matter. This tax matter involved an appeal against a KRA decision to decline the approval of a VAT refund application valued at KES 58 million.- APA Insurance and APA Global: This assignment involved a tax assessment raised by the KRA on APA General of KES 147 million and APA Life of KES 13.9 million. We were able to negotiate the tax demanded downwards by a margin ranging between 40 - 50%.- Kaptis Buchangu Power Project: This assignment involved preparing a tax schedule for Engie Power.- GH Tanna and Sons: This transaction involved the surrender by Barclays Bank Kenya Limited of the lease of premises in Nairobi to GH Tanna and Sons. By drafting this surrender, we were in a position to assist the client save a significant portion of tax that would otherwise have been lost had the surrender been structured as a business income.- World Bank - Private Equity and Venture Capital Recommendations in Kenya: This assignment involved the review of the tax and legal regime applicable to Private Equity and Venture Capital entities in Kenya. The aim of this assignment was to give reasons why the tax and legal regime in Kenya is not conducive for the establishment and operation of private equity and venture entities.- Karimjee Jivanjee Limited: This assignment involved the structuring of a regional business primarily based in Tanzania, looking to set up in the East African countries, such as Kenya, through a holding company in Mauritius.

Associate

• 2015 - Dec 2016

Select Assignments and Achievements:- Participated in the draft and review of Firm's Chambers Global submission for the year for tax. Anjarwalla & Khanna's submission was the only submission published from African law firms.- Hemingways Group re-organization: involved in the restructuring of different entities in the hospitality industry which was led by income tax, VAT, CGT, andstamp duty considerations.- Mara II Toto Structuring: This transaction centered on the development and sale of high end apartments and hotel premises in the Mara and it involved the use of an LLP in Kenya on account of its tax transparent status and its tax saving on compensating tax.- SICPA Agreement Review: This assignment involved the review of incoterms 2000, particularly DAP, as the rights and obligations of the KRA (Including tax implications) depended on DAP's interpretation. The assignment also involved the review of the law making process employed by the Council of Ministers in Arusha.- Safepak - Aracari Land Amalgamation: This transaction involved restructuring two related companies - Arakari and Safepak - which have common ownership; so that a parcel of land can be transferred from Aracari (subsidiary) to Safepak (shareholder) for purposes of amalgamation.- APA - VAT on Sale of Salvages: This assignment touched on an industry-wide issue revolving around the question of the VAT status of motor vehicle salvages sold by insurance companies in the course of indemnifying the insured upon the occurrence of a loss. This advice allowed APA to counter a KRA demand on an assessed liability on such trasactions.- Baharlwind - Electrawinds Structure: This assignment involved providing tax advice and drafting a services agreement for a power project in Vipingo.- Due Dilligence: This assignment involved assisting Equator Bottlers Ltd prepare documentation and information for Deloitte & Touche for a due diligence prior to a proposed share purchase of Equator by SAB Miller Intl.

Senior Tax Advisor

• Jan 2012 - Aug 2015

I was engaged broadly in tax compliance and advisory work both within the local environment and working in consultation with the EY international teams.Assignments and Achievements:- BRITAM acquisition of ACORN Ltd – conducted a full tax due diligence on the target, involving corporation tax, withholding tax, PAYE, customs and excise duty.- Provided a full tax advisory to Deutsche Lufthansa LSG on setting up a world class catering facility at JKIA to offer international airlines their catering services. The advice involved structuring of licence/royalty agreements for withholding and VAT and advice on the Permanent Establishment risks of working with the German head office.- Conducting the corporate tax review for Citibank NA, Kenya Branch, in consultation with the Citi London and Citi New York offices.- Providing human capital and payroll advice for I Way Africa, Tredcor Africa, IBM and Schlumberger Offshore Services Limited.- Conducting VAT compliance services for Kenya Airways Ltd., Galana OilKenya Ltd., General Electric, Syngenta Ltd and Inchcape Shipping Services Ltd.- Providing structuring advice to Africa Infrastructure Investment Managers in Mauritius, Kenya and South Africa demonstrating how to invest in infrastructure projects in Kenya through foreign financing.- Assisting East African Portland Cement Company Ltd in challenging a KRA Assessment involving Withholding tax, Value Added Tax and Corporation tax and particularly with regard to the definition of exports and their charge to VAT of exports; the definition of agents and distributors and the tax status of commissions.

Intern

• Jul 2011 - Dec 2011

Legal advisory. Legal advisory.

Editor

• Jan 2009 - Jan 2011

Sub Editor

• Jan 2010 - Aug 2010

Personal Financial Advisor

• Sep 2009 - Mar 2010

Financial advisory. Financial advisory.