Friday, 11 November 2016

Income Tax, Kenyan Tax Law

By Kavosa Assava, LLB
Income Tax
·         S. 3 (1) – Income tax; charged for each year of income; whether resident or non-resident; accrued or derived from Kenya.
·         S. 3 (2)- what is chargeable as income tax?
·         S. 5 – when income from employment is deemed to be accrued or derived from Kenya; this gives two scenarios;
1.        Resident; S. 5 (1) (a) ; in or outside Kenya
2.       Non- Resident S. 5 (1) (b); only if you work for a Kenyan Employer; a non-resident is taxed where he or she renders employment for a Kenyan employer or a Permanent Establishment.
·         S. 2; definition of ‘Permanent Home.’
·         A permanent establishment is a business not registered in Kenya but operates its business within Kenya and has done so for at least 6 months.
·         What should be included in your employment income? S. 5 (2) (a)
1.        Salaries
2.       Wages
3.       Allowances; hardship, entertainment, housing, car loans, school fees, insurance, security, food, vacation, leave. E. t.c
·         S. 5 (2) (a) (ii); any reimbursement from the employer is not considered part of your salary and hence is not taxable- where you spend your own money in the course of employment and your employer pays you back.
·         S. 5 (2) (a) (iii); the first 2000 of reimbursement is tax- free; any amount above that has to be evidenced by receipt before exemption from tax is granted.
·         Benefits received from employer that are below 36000 per year are exempt from tax.
·         An employee is not liable if an employer fails to deduct tax.
·         S. 5 (2) (B); Car allowance- 2% of initial cost of the car; that amount is added to the salary and the taxed; for tax purposes, the car never depreciates.
·         Some employers will hire a car for the employee; alternatively the car may never sleep at the employee’s residence.
·         Airtime; 30% of the total on personal consumption. It is this 30% of value of airtime that is determined and added to salary for taxation.
·         Housing: the higher of three things is taxed;
1.        Market Rate
2.       15% of [ salary + Taxable benefits ]
3.       How much employer is paying for rent
·         When an employer gives an employee money it is added to the basic salary and then subjected to tax; i. e. duty allowance or entertainment allowance.
Tax exempt
·         Medical benefits are not taxable
·         School Fees: If employer pays school fees for employees children, it  is tax free
·         Passages are not taxable; In recruitment of expatriates, buying the air ticket. However where employer gives employee the money to buy the ticket, it is taxable.
·         Meals: Provision of meals at the business premises is tax free up to a maximum of 4000 per month or 48000 per year, per employee.
·         Home Ownership Savings Plan- only taxed at date of withdrawal; you can only save a maximum of 48,000 a year; if you exceed this it is taxable.
Deductions
·         Mortgage Interest Deduction- If an employee is paying a mortgage then he or she can deduct the interest before subjecting salary to taxation. The maximum is 150, 000 per year or 12,500 per month. [s.15(3)(b)] It must be a residential home and he must be living in it at the time in order to effectuate the deduction.
·         Pension- pension contributions are deducted from salary before taxation; the employee makes a contribution and the employer matches it; the maximum pension deduction allowed is 20,000 per month or 240,000 per year. It is taxed at withdrawal the total at the normal rate unless you wait until 65 years of age where it will be tax-free.
·         The 20,000 max is shared between the employer and the employee. However, the employee has priority in terms of the benefit of deduction.
·         Personal relief: Personal Relief is deducted from the tax liability. [ P.a = 13,944; P.m = 1,162 ]
·         Where an employee is terminated before the contract of service expires, he or she is entitled to an amount in compensation for the remaining years. The compensation is spread out evenly for the remaining term under the contract.[ Specified Term + Specified compensation = Spread Out Evenly for remaining contract]
§  Where there is an unspecified term of employment under the contract but there is a specific amount allocated as compensation, the amount is spread at the rate of earnings or salary of the employee according to how he or she was being paid per annum.[ Unspecified Term + Specified Compensation= Spread out at rate of earnings per year.]
§  Where there is neither a specified term under the contract nor a specified amount allocated as compensation, the compensation is spread out for 3 years.[Unspecified Term + Unspecified Compensation= Spread Out evenly for three years]
Revision Notes
The distinction Between Contract of Service and Contract for Services
The line between whether an individual is employed or self-employed is a grey one. Generally;
§  A contract of service between two parties implies a contract of employment exists
§  A contract for service between two parties implies the self-employed status of the service provider.
The key issue is that a contract of service obliges the employer to operate PAYE as the employee is taxable and the employer carries all the associated tax responsibilities. Under a contract for service the individual is liable to tax and the person making the payment to him has no responsibilities associated to tax with regards to that transaction.
There are certain tests that have been applied to determine whether an individual is employed or self-employed and they include;
1.     The Control Test
2.    The Supplier’s Own Business Test
3.    The Economic Test
The Control Test: To determine the relationship between the two parties the element of control that the employer can exercise over the employee must be reviewed. In the Irish case Roche v Kelly [1969] IR 100 it was held that the right of the master to direct the servants as to what and how the work is to be done was a main factor in determining the relationship between the parties. The case arose out of an injury suffered by an individual during the construction of a barn for a farmer. The question was whether the injured party was an employee of the farmer. The right to interfere with how the individual carried out their work and the fact that the farmer did not exercise control over the individual were important findings and became known as the control test.
It is not always clear whether this level of control applies, as was demonstrated in a later Irish case of Re Sunday Tribune [1984] HC. The difficulties in the control test were recognized where skilled workers were told what to do but not how to do it. In this case two journalists were doing similar work. The distinction was in how the work was done by each journalist. It was held that one was an integral part of the Sunday Tribune while the other was a freelance contributor.
Obviously further clarification was required and additional tests were laid down following the case of Ready Mix Concrete (SE) Ltd v Minister of Pensions and National Insurance [1968] 2 QB 497 i.e.
§  Mutual Obligations Test- If there is no obligation on the employer to offer work or on the other party to do work, there is no contract of service.
§  Whether the employee agrees that he will be subject to the other’ s control expressly or impliedly to a sufficient degree to make the other party his employer.
§  Whether the provisions of the contract are consistent with it being a contract of service
In this case the individuals had been previously employed as drivers by Ready Mix Concrete. They entered into a different relationship; they leased the lorries under one contract and agreed to deliver concrete under another contract for the company. Their new obligation was to deliver in their own lorries. The drivers were determined to have contracts for service and be taxed as self-employed.
The Supplier’s Own Business Test: A major difference in employed v self-employed is the question of the performance of the service as a person in business on their own account. The UK case of Market Investigations Ltd. V Minister of Social Security [1969] 2 QB 173 established some important factors in considering if a contract of or for service exists, namely:
§  Does the person performing the services supply his equipment?
§  Can he hire his own helpers?
§  What opportunity does he have to make a profit?
§  To what extent does he carry the responsibility for investment/management?
If the individual supplies the equipment, the staff, takes the risk and manages the business he is acting in the capacity of self-employed and not employee.
The Intention of the Parties: The facts of each case will determine whether the contract is of or for service. However, the intentions of the parties cannot be overlooked and may be important.
The Economic Test: The case of Henry Denny & Sons (Ireland) Ltd. V Minister for Social Welfare[HC 1995] [SC11998] 1 IR 34 considered various tests and criteria in determining the status of the contract. It introduced the economic test which examines if the individual is economically independent from the person requiring the work to be done.
The case related to the status of a supermarket demonstrator whose job was to offer free samples to shoppers. The demonstrator was paid by the supplier of the free samples. Tests applied were:
§  Control test- the demonstrator was found to be under the control and direction of and could be dismissed by the employer.
§  Integration test- (integral to the business) she was considered to be an integral part of the supplier’s business.
§  Own Business test- she was found not to be in business. She could not profit from her services.
§  Economic test- the engagement terms were consistent with those of a contract of service. She was not supplying equipment, or taking risk.

·         Marina et al. (2002) argue that, “taxation is the only known practical manner for collecting resources in order to finance public expenditure for goods and services consumed by any citizenry”.
·         Taxation in Kenya is governed by the provisions of the Income Tax Act Cap 470- Laws of Kenya.
·         Prior to this taxation was governed by the East African Management Act of 1958 which was in force in all three East African countries until the EAC split.
·         Income tax is a direct income.
·         Every person with a taxable income is required to have a Personal Identification Number [PIN]. It is a personal number given to any person with an income chargeable to income tax.
·         The law also makes it mandatory to have a PIN for certain transactions which are listed in the Act such as motor vehicle transfers, clearing of goods with the customs service department, new installation of water and electricity metres among others.
·         Methods of collecting tax:
o   Pay As You Earn[PAYE]
o   Withholding tax
o   Instalment tax
o   Advance tax
o   Presumptive Income Tax [PIT]
o   Direct payments to the Commissioner of Domestic Taxes for balance of tax and arrears
Pay As You Earn [PAYE]
·         Method of collecting tax at source from individuals in gainful employment.
·         The employers will deduct tax according to the prevailing rates of tax from their employee’s salary or wages on each pay day for a month then remit the tax to the Paymaster- General through the laid down procedure on or before the 9th day of the following month.
·         The employee thus has no extra liability to pay at the end of the year unless he has income from other sources including other employments
·         PAYE tax payments help to spread evenly the tax burden for those in gainful employment, throughout the calendar.
·         Every individual in receipt of income liable to income tax is entitled to relief known as personal relief, granted against tax payable and is not refundable to a tax payer.
·         Unutilized personal relief can be carried forward from one month to another within the same calendar year but not from one year to another.

Tax Incentives
·         For individuals include:
o   Personal relief
o   Relief paid on premiums for Life Insurance
o   Relief/deduction of interest paid on Mortgage for owner-occupied house.
o   Relief/deductions of funds deposited under a Registered Home-Ownership Savings Plan, Subject to a maximum of 48,000 per year.
o   Tax exemption on Interest accruing on housing bonds up to a maximum of 300,000 shillings
o   Tax exemption on contributions to registered provident funds and no charge to tax on the first 480,000 on a lump sum committed from a registered pension or provident fund.
·         For Corporations include:
o   Capital Deductions;
o   wear and tear;
o   Industrial building allowance in respect of capital expenditure on hotel buildings and other industrial buildings;
o   capital expenditure on Farm works;
o   Investment allowance
·         EPZs enjoy the following benefits:
o   10 year tax holiday from corporation tax
o   A lower corporation tax of 25% for the subsequent 10 years
o   Exemption from withholding tax on dividends and other payments to non-residents during the first 10 years.
o   Investment deductions at 100% of capital expenditure claimable in the 11th year after commencement of production.
·         The tax base is all items or activities subject to a tax.
·         It is important to distinguish between the potential tax base and the actual tax base.
·         Potential tax base constitutes a set of items that would be taxed if there were no special exemptions; whereas the actual base what is used, given exemptions and other benefits and it is often much smaller.
·         Tax base is measured to the shilling amount to which a tax rate is applied. •
·         The tax rate is usually defined as a percentage of a certain value - the tax base.
·         Therefore, multiplying say a VAT tax rate of 16% on a taxable item such as a pair of shoes (tax base) worth Ksh. 2,000, the total amount of tax to be collected from this purchase amounts to Ksh 320. •
·         Tax burden - refers to the amount of tax borne by an individual or a business.
·         Tax burdens vary depending on a number of factors including income level, jurisdiction and current tax rates.
·         It is worth noting that tax burden may not be the same as the tax actually paid because of the possibility of passing a tax on.
·         This distinction helps explain who has the legal liability of a tax-who has the “statutory burden” and who actually bears the ultimate burden of the tax-who has the tax burden i.e. bears the economic incidence of the tax •
·         The average tax rate is calculated by dividing the total income taxes paid by your total income. •

·         The marginal tax rate is the rate of tax applied to the last shilling added to your taxable income

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