Karanja Njenga Advocates

Are County’s Own Source Revenue Taxable?

In County Government of Kiambu v Commissioner of Legal and Board Services (Tax Appeal E812 of 2025) [2026] KETAT 71, the Tax Appeals Tribunal has provided much-needed clarity on the taxation of County Governments.

Key outcomes:
County Own Source Revenue is not subject to VAT; public service is not a business. Official airtime & imprests are not taxable employment benefits. Pool vehicles must be supported by logbooks to avoid PAYE assessments. KRA must provide substantiated reasons when confirming tax demands.

A vital precedent for all 47 counties in Kenya.

Read the full analysis to understand what this means for devolved units.

Click here to access the full update.