The Finance Bill 2025 proposes several updates to Kenya’s Tax Procedures Act (TPA) signalling the Kenya Revenue Authority’s (KRA) growing emphasis on compliance enforcement, information access, and administrative streamlining.
Whether you are a business owner, tax consultant, or just a taxpayer, these changes could directly impact your operations, rights, and responsibilities.
Let’s break down the key updates.
1. KRA to Access Joint and Non-Resident Bank Accounts
In a bold move, the Bill grants expanded powers to KRA — enabling it to:
Access joint bank accounts and non-resident accounts for tax enforcement purposes.
Previously, KRA often faced legal and logistical hurdles when trying to collect taxes from individuals using shared or offshore banking structures.
Under the proposed changes:
- KRA can issue agency notices on such accounts
- Taxpayers with foreign or joint financial arrangements should be prepared for increased transparency
Implication: Multinational firms, high-net-worth individuals, and expats could face greater scrutiny, especially those with offshore accounts.
2. Agency Notices Allowed Even During Tax Appeals
One of the more controversial proposals is that:
KRA can now issue agency notices (e.g. to banks or employers) even while a tax appeal is ongoing.
Currently, taxpayers under appeal enjoy a temporary reprieve from such collection actions. This proposal removes that buffer, giving KRA the power to recover contested taxes before resolution.
Concern: Critics argue this undermines taxpayer rights and may discourage legitimate appeals.
3. Extended Timelines for Refunds and Audit Reviews
The Bill proposes lengthening administrative windows to give KRA more time to process:
- Tax refunds:
From 90 days → 120 days - Audit reviews:
From 120 days → 180 days
Why it matters:
While the intention is to improve accuracy and reduce rushed decisions, it could also mean longer waits for taxpayers seeking refunds or finality in audits.
4. Mandatory Reasons for Amended Tax Assessments
In a step toward transparency, the new law will require:
KRA to provide reasons when issuing amended assessments.
This protects taxpayers from vague or unexplained demands and aligns with principles of administrative justice.
Win for taxpayers — this gives businesses a clearer understanding of their obligations and grounds for appeal.
5. Relief from Double Penalties in Some Withholding Tax Cases
The Bill introduces relief where:
A taxpayer fails to withhold, and the recipient has already paid the tax.
Currently, both parties can be penalized — leading to double taxation. Under the update, KRA must consider whether tax has already been paid before applying penalties.
Fairness Win: This change could protect employers, agencies, and vendors from disproportionate punishment.
6. Stamp Duty Removed for KRA Notifications on Property
Lastly, the Bill removes the requirement to pay stamp duty on KRA notifications involving property — particularly when:
- KRA is notifying parties of a tax claim against land or property
- The property is flagged for enforcement
This simplifies compliance and removes an additional cost in the enforcement process.
What This All Means
The changes reflect KRA’s shift toward tighter tax control, broader powers, and more aggressive collection tools — especially in an economy recovering from global and domestic pressures.
Key Takeaways:
| Change | Impact |
| KRA access to joint/non-resident accounts | Broader enforcement power |
| Agency notices during appeals | Reduced taxpayer protection |
| Longer timelines for refunds/audits | Delayed resolutions |
| Reasons for assessments required | Increased fairness |
| Relief from double withholding penalties | Reduced double taxation |
| Stamp duty removal | Faster property enforcement |
While some proposals improve transparency and fairness, others shift power heavily toward the KRA. Businesses and individuals must review their tax strategies, maintain cleaner records, and stay alert to enforcement risk — especially for joint accounts, offshore holdings, and pending appeals.
Tax experts, legal advisors, and CFOs should prepare for a more intrusive and procedural tax environment — and adapt early.