Report Of Dc - Finance & National Planning On The Income Tax (amendment) Bill, 2026

THENATIONALASSEMBLY

THIRTEENTHPARLIAMENT-FIFTHSESSION-2026

DIRECTORATEOFDEPARTMENTALCOMMITTEES

DEPARTMENTALCOMMITTEEONFINANCEANDNATIONALPLANNING

REPORT ON:

THECONSIDERATIONOFTHEINCOMETAX(AMENDMENT)BILL (NATIONALASSEMBLYBILLNO.20OF2026)

TEIE NATIONAL ASSEMBLY PAPERSLAID

Published by:

DATE:

28 APR 2026

DAY.

TVECDA

TABLED

HNKURIAKImAotI

The Directorate of Departmental Committees':

CHAIQPERSON

Clerk'sChambers

Parliament Buildings NAIROBI

CLERK-AT THE-TABLE:

IN2OFU MWALE

APRIL2026

TABLEOFCONTENTS

| ANNEXURES | |------------------------------------------------------------------------------| | CHAIRPERSON'SFOREWORD | | CHAPTERONE. | | IPREFACE | | I.IESTABLISHMENTANDMANDATEOFTHECOMMITTEE | | 1.2COMMITTEEMEMBERSHIP | | I.3COMMITTEESECRETARIAT | | CHAPTERTWO | | 2.0OVERVIEWOFTHEINCOMETAX(AMENDMENT)BILL(NATIONAL ASSEMBLYBILLNO.20OF2026).. | | 2.1Background. | | 2.2Summary of Legal Provisions | | CHAPTERTHREE | | 3.PUBLICPARTICIPATIONANDSTAKEHOLDERENGAGEMENTONTHE BILL | | 3.ILEGALFRAMEWORKONPUBLICPARTICIPATION | | CHAPTERFOUR. 30 | | 4COMMITTEEOBSERVATIONS .30 | | CHAPTERFIVE 31 | | 5COMMITTEERECOMMENDATION 31 |

LISTOFABBREVIATIONSANDACRONYMS

COK

Constitution of Kenya

ICPAK

InstituteofCertifiedPublicAccountantsofKenya

IPF

InstituteofPublicFinance

KISM

Kenya InstituteofSuppliesManagement

LSK

Law Society of Kenya

MP

MemberofParliament

OCOB

Office of the Controller of Budget

ODM

OrangeDemocraticMovement

PWC

PricewaterhouseCoopers

UDA

UnitedDemocraticAlliance

IPREFACE

I.IESTABLISHMENTANDMANDATEOFTHECOMMITTEE

• I)TheDepartmentalCommitteeonFinanceandNationalPlanning isoneof twenty departmentalcommitteesoftheNationalAssemblyestablishedunderStandingOrder216 whosemandatepursuanttotheStandingOrder216(5)isasfollows:
• a)To investigate,inquire into,and report on all matters relating to the mandate, management,activities,administration,operations and estimates oftheassigned ministriesanddepartments;
• b To study the programme and policy objectives of ministries and departments and the effectivenessoftheimplementation;
• To,onaquarterlybasis,monitor andreport on the implementationof the national budget in respect of its mandate;
• P Tostudyandreviewall legislationreferredtoit;
• Tostudy,assessandanalysetherelativesuccessoftheministriesanddepartments as measuredbytheresultsobtainedascomparedwiththeirstatedobjectives;
• f Toinvestigateandinquireintoallmattersrelatingtotheassignedministriesand departments as they may deem necessary,and as may be referred to them by the House;
• g) Tovet andreport onall appointmentswheretheConstitutionor any lawrequires the National Assembly to approve, except those underStanding Order 204(Committee on Appointments);
• i) To make reports and recommendations to the House as often as possible, including recommendations of proposed legislation;
• h)To examine treaties,agreements and conventions;
• j Toconsiderreports ofCommissions and Independent Offices submitted to theHouse pursuanttotheprovisionsofArticle254oftheConstitution;and
• k)To examine any questions raised by Members on a matter within its mandate.
• 2.The Second Schedule to the National Assembly Standing Orders assigns the Committee the mandate to consider matters in relation to public finance, public audit policies, monetary national statistics, population, revenue policies including taxation, national planning and
• 3.In executing its mandate, the Committee oversees the following Ministries/Departments:
• i) TheNational Treasury.
• i) StateDepartmentforPublicInvestmentsandAssetManagement.
• i) StateDepartmentforEconomicPlanning.
• iv) TheCommissiononRevenueAllocation(CRA)
• V) OfficeoftheControllerofBudget

CHAPTERONE

I.2COMMITTEEMEMBERSHIP

1. TheDepartmental Committee on Finance and National Planning was constituted by the House on 27h October 2022 and reconstituted on Wednesday,5th March 2025 and comprises the following Members:

Chairperson

Hon.FCPA Kuria Kimani, CBS, MP Molo Constituency UDA Party

Vice-Chairperson

UDA Party Members

Hon. (Amb.) FCPA Langat Benjamin Kipkirui, CBS, MP Ainamoi Constituency

Hon.Peter Kaluma, CBS,MP Homa Bay Town Constituency ODM Party

Hon. Sunkuyia, R. George, MP Kajiado West Constituency UDA Party

Hon.FCPA Oyula,Joseph H.Maero,MP ButulaConstituency ODM Party

Hon. Betty N. Maina, MP

Murang'a County UDA Party

Hon.Mboni,David Mwalika,MP Kitui Rural Constituency

Hon.Sheikh Umul Sheikh,MP Mandera County UDM Party

WDM Party

Hon.Okuome Adipo Andrew,MP Karachuonyo Constituency ODM Party

Hon. (Dr.) Shadrack Mwiti, MP South Imenti Constituency Jubilee Party

Hon. Chiforomodo, Munga, MP Lunga Lunga Constituency UDM Party

Hon. (Dr.) Ariko John Namoit, MP TurkanaSouth Constituency ODM Party

Hon. CPA Rutto Julius Kipletting, MP Kesses Constituency UDA Party

Hon.Machele M. Soud, MP Mvita Constituency ODM Party

Hon. Paul Biego, MP

Chesumei Constituency UDA Party

I.3COMMITTEESECRETARIAT

• 4.TheCommitteeisfacilitatedbythefollowingstaff:

Ms. Tracy Chebet Principal ClerkAssistantII

| Ms.Jennifer Ndeto Deputy Director Legal Services | Mr. Benson Kamande ClerkAssistantII | |----------------------------------------------------|-------------------------------------------| | Mr.Salem Lorot Senior Legal Counsel | Ms.WinfredKambua ClerkAssistantIII | | Mr. George Ndenjeshe Fiscal AnalystII | Ms. Nelly W. Ondieki Research Officer III | | Mr.Eugene Luteshi AudioOfficerIII | Mr. James Macharia MediaRelationsOfficer | | Mr.Benson Muthuri AssistantSerjeant-At-Arms | Ms. Joyce Wachera Hansard Reporter II |

Mr. Allan Ngugi Admininstrative OfficerIll

CHAPTERTWO

2.0OVERVIEW OF THEINCOMETAX(AMENDMENT)BILL(NATIONAL ASSEMBLYBILLNO.20OF2026)

2.1Background

• 5.The Income Tax(Amendment) Bill (National Assembly Bill No. 20 of 2026) is a Bill sponsored by Hon.FCPA Kuria Kimani, CBS,MP.The Bill was published on 2"d April 2026vide Kenya Gazette Supplement No. 100 of 2026. The Bill was then committed to the Committee for its considerationandtablingof thereporttotheHousepursuanttoStandingOrder127.

2.2SummaryofLegalProvisions

• 6.Theprincipalobjectof thisBill isto amend theIncomeTaxActtoprovideforexemptionof capitalgainstaxinthe transferofpropertybya company toits shareholdersaspartof an internal reorganization,oron thetransferofpropertytothecompanybytheshareholders as considerationforthetransfer.
• 7.Currently, under the Eighth Schedule to the Income Tax Act, transfers of property between acompanyand its shareholders aregenerallysubject toCapitalGainsTaxwheresuch transfersresult ina disposal for taxpurposes.This means thatevenwhere a company undertakesinternalrestructuringinvolvingthetransferofassetswithinthesameeconomic group, such transactions may still attract Capital Gains Tax if they fall within the definition of achargeabletransfer.
• 8.The proposed amendment introduces a new exemption under item 6 of the Eighth Schedule s shareholders,as part of an internal reorganisation,shall not be subject to Capital Gains Tax, distributedinproportiontotheshareholders'existingshareholdingimmediatelybeforethe transfer,andwheresharesareinvolved,theymustrelate toa subsidiaryofthecompany undertaking the reorganisation.
• 9.At present,the Income Tax Act does not define the term"internal reorganisation"for purposes of the Eighth Schedule. This lack of definition creates uncertainty in determining whichtransactionsqualifyfortaxrelief andmay exposetaxpayerstodifferinginterpretations by tax authorities.Insomecases,thisambiguitymay leadtodisputesregardingwhether a particularrestructuringqualifiesforexemptionorconstitutesataxabledisposal.
• 10.The Bill also defines "internal reorganisation." Under the proposed Bill, internal reorganisation is defined as any restructuring of the ownership,control, or assets of a definition is to limit the exemption strictly to intra-group transactions, thereby ensuring that onlygenuineinternalrestructuringexercisesqualifyforreliefwhileexcludingtransactions involvingexternalparties.

• Il1. Under the current provisions of Section 7 of the Income Tax Act, certain distributions made by a company to its shareholders may be treated as dividends for income tax purposes and therefore subject totaxation.In situations wherea companyundertakes restructuring involvingthetransferof assetstoshareholders,suchtransferscouldpotentiallybereclassified asdividends,dependingontheirnatureandstructure.

12. The proposed amendment to Section 7 provides that transfers of property made under the treated as distributions for purposes of income tax.The effect of this provision is to prevent such transactions frombeing classified as dividends,thereby ensuring that they are not subjectedtoincometaxunderSection7.

CHAPTERTHREE

3.PUBLICPARTICIPATIONANDSTAKEHOLDERENGAGEMENTONTHE BILL

3.ILEGALFRAMEWORKONPUBLICPARTICIPATION

• 13.Article Il8 (l)(b) of the Constitution provides that:

"Parliament shall facilitate public participation and involvement in the legislative and other businessofParliamentanditsCommittees."

14. The National Assembly Standing Order I27 (3) and (3A) stipulates that: 2. "(3)TheDepartmentalCommitteetowhichaBilliscommittedshallfacilitatepublic 3. (a)invitingsubmissionofmemoranda; 4. (b) holding publichearings; 5. (c) consultingrelevant stakeholders in a sector;and 6. (d)consultingexpertson technicalsubjects. 7. (3A)TheDepartmentalCommitteeshall takeintoaccounttheviewsandrecommendationsof the public under paragraph(3) in its report to the House."

3.2MEMORANDARECEIVEDONTHEBILL

15. Pursuant to the aforementioned provisions of law, the Clerk of the National Assembly placed anadvertisementintheprintmediaon17hApril2026inviting thepublictosubmit memoranda on the Bill.Further,the Clerk of the National Assemblyvide letter Ref NA/DDC/F&NP/2026/069dated20April2026invitedkeystakeholderstosubmitviewson theBill and attend a publicparticipation forum on 24hApril 2026respectively. 2. 16.The Committee received twelve memoranda from the following stakeholders:

• i) KPMG;
• i) PricewaterhouseCoopers (PWC);
• i) Bowmans;

6. The Law Society of Kenya (LSK); 7. iv) SKM Africa; 8. vi) WeCare CBO; 9. vii) Westminister Consulting LLP; 10. viii) Oxfam Kenya; 11. ix) Deloitte&ToucheLLP; 12. (x ErnestandAssociates; 13. xi) Kenya Institute of Supplies Management (KISM); and 14. xii) Office of the Controller of Budget(OCOB).

Clause2

17. KPMG supported the proposal noting that this provides welcome cash-flow relief for entities undergoinginternal reorganizations by exempting deemed dividendsfromwithholding tax (WWHT) where a company transfers assets, including shares, to its shareholders. This exemptionallowscompaniestosimplifytheiroperationalorownershipstructureswithout concern thatKenya's taxframeworkhashistoricallydiscouraged legitimateintra-group restructuringsbytreatingsuchtransfersastaxabledistributionevents. 2. I8. Bowmans supported the proposal noting that this is an important clarification as it would companytoitsexistingshareholdersinproportiontotheirexistinginterests. 3. 19.SKM Africa supported the proposal. They observed that this a timely amendment as it ensures that internal reorganisations will no longer trigger deemed dividend treatment, eliminatingwithholding tax costswherenoshareholder enrichment occurs.It alsoaligns tax treatmentwitheconomicsubstancebyrecognisingthatinternalrestructuringsdonot constituteprofitdistributionstoshareholders. 4. 20.LSK notedthat the amendmentworksin tandemwithproposedchanges tothe Eighth Schedule exempting qualifying internal reorganisations from Capital Gains Tax. The Law amendment represents a positive step toward facilitating corporate reorganizations by introducingexemptionsintendedtoremoveimmediatetaxbarriers. 5. 21.Theyproposedexpresslyexcluding transfersthatqualifyfor thereorganizationexemption fromtheapplicationofParagraph8(4A)of TheEighthScheduleto theIncomeTaxAct.This ensures neutralityby not deferring orshifting theburden tothetransferee andremoves the commercialconstraint.

PricewaterhouseCoopers Limited (PWC)

• 22.Amend the proposed section 7(1)(c) to read as follows: "Notwithstanding paragraphs (a) and (b), a transfer of property by a company to its

shareholdersunderparagraph6(2)(i)of theEighthScheduleshallnotbedeemed tobea dividend distribution for the purposes of this Act."

• 23.They noted that the current drafting does not clearly disapply deemed dividend treatment under section 7,andwhereas clarifying theterminology ensures that qualifying internal reorganisations remain tax-neutral, the amendment will enhance draftingprecision,reduce interpretivedisputeswiththeKenyaRevenue Authority,andstrengthencertainty for taxpayers.

CommitteeObservation:

The Committeenoted theproposal seeking to amend the drafting toexpressly clarifythat"distribution"refersto"dividend distribution"forpurposes ofsection7 oftheIncomeTaxAct.TheCommitteeagreedwiththestakeholder thatthe proposed amendment is clarificatory in nature and enhances precision in drafting byremovingambiguityintheapplicationofdeemeddividendtreatmentto qualifying internal reorganisations under paragraph 6(2)(i) of the Eighth Schedule.

WeCareYouthOrganization

• 24.Amend the proposal as follows:-

Providedthatatransferunderparagraph(c)shallonlyqualifyfornon-distributiontreatment wheretheCommissionerissatisfiedthat:

• (i)thetransfer is undertaken for genuine commercialpurposes and notfor the avoidanceofincometaxorCGT
• (i)thecompany has notified the Commissionerof the reorganisation inthe prescribedformwithinamaximum30daysofcompletionand
• (ii)No artificial arrangement has been done to inflate the value of thetransferred property.

25. This amendment is to introduce conditions requiring that qualifying transfers be undertaken for genuine commercial purposes,be reported to the Commissioner within a prescribed timeline,andnotinvolve artificialvaluationarrangements,sinceexcludingsuchtransfersfrom tax-free, thereby undermining equity and eroding the tax base.

CommitteeObservation:

The Committee noted the concerns regarding possible abuse of the exemption. However, the Committee was of the view that these concerns are adequately addressedunderexistinglaw,includingSection23oftheIncomeTaxActontax avoidance arrangements and theTaxProceduresAct,2015,whichprovides for reporting,complianceandenforcementmechanisms.TheCommitteeobserved thatembedding additional safeguardswithin this clausewould duplicate existing wasthereforenotadopted.

WestminsterConsultingLLP

• 26.Amend theproposal toprovidethat transactionsundertakenpursuanttoa qualifyinginternal reorganisation shall not be deemed toconstitute a dividend.This should applywhether the entry,credit,allocationor otherform ofvalue transfertoshareholders.This amendmentis necessarybecause the current draftinglimits relief tophysical transfers ofproperty.It does notcaptureaccounting-basedrestructuringssuchasthereclassificationofreservesor creditingofshareholderaccounts.Atthesametime,thedefinitionofdividendundertheAct

alreadycoverssuchvaluemovements.Thiscreatesinconsistenttaxoutcomes for transactionsthatareeconomicallyidenticalbutdifferonlyinform.Expandingtheprovision will ensure tax neutrality and eliminate interpretational gaps.

CommitteeObservation:

TheCommitteenotedtheproposal tobroadenthescopeoftheexemption. However,theCommitteewasoftheviewthattheamendmentasdrafted,read togetherwiththedefinitionofdividendunderSection2andSection7ofthe Committee further observed that any administrative clarification on the applicationmaybeaddressedthroughregulationsorguidancebythe Commissioner,and therefore,no amendmentwas necessary.

OxfamKenya

• 27.Amend theclause asshownbelow:-
• i.Add a wealth/income qualifier. The CGT exemption under this clause should apply onlywherethetotalmarketvalueof assetstransferredtoanysingleshareholderdoes notexceedKsh50million(tobereviewedevery3yearsbytheCabinetSecretaryon adviceofKRA).
• ii. Insertasunsetclausetoprovidethattheprovisionshouldlapse5yearsafter enactmentunlessrenewedbyParliamentfollowingarevenueimpactreview.
• ili. Add a mandatory disclosure requirement that,companies relying on this exemption mustsubmit acompletedreorganisationdisclosureForm toKRAwithin30days. (Kenya's Tax Procedures Act, Cap. 469B prescribes 30-day notification windows for several compliance obligations,so it is internally consistent with the existing framework)of the transfer,detailing the nature of the reorganisation,total value transferred, and identities of recipient shareholders.

28. They noted that the current provision applies uniformly regardless of transaction value and maydisproportionatelybenefithigh-net-worthindividuals,while theabsenceofperiodic promoteprogressivetaxation,enhancetransparency,andenableeffectivemonitoringbythe Kenya Revenue Authority.

CommitteeObservation

The Committee notedthe proposal seeking additional safeguards through thresholds,reviewmechanisms,anddisclosures.However,theCommitteewas of the view that imposing transaction value caps or sunset clauses would undermine certainty and predictability in taxation, contrary to Article 20l of the Constitution, and may reintroduce distortions that discourage legitimate reorganisations andwillstillcause fragmentation.TheCommittee further observed that disclosure obligations are alreadyprovided for under the Tax Procedures Act, 20l5,and need not be duplicated in this amendment. The proposalwasthereforenotadopted.

Westminster Consulting LLP

Clauses2and3

• 29.Amend this provision to clarify that the exemption applies to all forms of internal as those effected through accounting entries andvaluereallocations.This clarificationis important because modern corporate restructurings are often executed througha combination of legaland accounting mechanisms.Limiting the exemption to form-based transactionscreatesadisconnectbetweenthelawandcommercialpractice.Extendingthe scope willensure consistent treatment of allqualifyingreorganisations basedon their economic substance. Additionally, adopting a substance-based framework will enhance coherence, reduce complexity, and improve predictability in tax treatment, as well as align theexemptionframeworkwithinternationalbestpractice.

CommitteeObservation

The Committee noted the stakeholder's proposal but was of a different view that theprovisionsintheBillweresufficientandthattheyaddressthestakeholder's concerns.

Clause3(a)

• 30.KPMGsupported theintroductionofa tax-neutralregimeforinternalreorganisations involving a company and its shareholders.They stated that this proposed exemption extends relief to entities conducting internal restructurings outside a formal group context, provided 13oftheEighthScheduletotheIncomeTaxAct.

31. However, they noted that the proposed relief is conditional on property being transferred to shareholders in proportion to their respective shareholdings. Any disproportionate transfer, even within the same group, falls outside the exemption and remains subject to tax. This Where the transferred property consists of shares, those shares must be in a subsidiary of the transferring company. The relief, therefore,does not extend to transfers of shares in unrelatedcompaniesorassociates.

• 32.Bowmans were in support of the provision, noting that it introduces a useful capital gains taxreliefforgenuine internalreorganisations.Theyobserved thatthereis aneed toprovide clarificationthatthereliefappliesirrespectiveofwhether the shareholders arerelatedor unrelated,providedtheconditionsintheclausearemet.
• 33.SKM Africa stated that this proposal is a welcomereform thatwill facilitate efficient internal reorganization within corporate structures.Businesses can restructure,consolidate,or

realignoperationswithoutincurringunintended taxoutcomes.Thisenhancesflexibilityin doing business. They noted that the proposal is consistent with modern tax policy principles thatseektotaxrealeconomicgains.

OCOB

• 34.TheController ofBudgetnoted thatCGTisa constitutionallysanctionedrevenue stream appropriatedthroughFinance Acts.ApermanentCGTexemptionforinternal reorganisations,without a sunset clause or review mechanism,creates an open-ended revenuerisk.Additionally,OCOBobservedthatthereversetransferlimb(shareholdersto company)couldbe susceptible to abuse wherepropertyis cycledthrougha nominally 'internal' reorganisation to achieve a tax-free uplift in the cost base of assets, potentially erodingtheCGTbasewithoutgenuinecommercialrestructuring.
• 35.Theyproposedintroducing
• a)amandatory3-yearpost-enactmentreviewoftherevenueimpactofthe exemption;
• b 500millioninassetvalue)obtain an advancerulingfromKRAbeforetheCGT exemptionapplies,and
• an anti-avoidanceprovisionrequiring that theproperty transferredback be the sameoradirectlytraceableasset,andthatthereorganisationnotresultina changeofultimatebeneficialownershipwithin5yearsofcompletion.

CommitteeObservation

TheCommitteenotedtheconcernsraised by theOfficeof theControllerofBudget. However,theCommitteewasoftheviewthattheIncomeTaxAct(Cap.470),the Tax Procedures Act,2ol5,and existing administrative enforcementmechanisms alreadyprovidesufficientsafeguards against tax avoidance,including the Commissioner's powers of audit, assessment, and application of anti-avoidance provisionsunderSection23oftheIncomeTaxAct.

The Committee further observed thatintroducing statutory advance ruling thresholds,mandatorypost-enactmentreviews,and extended ownership continuity tests within this provision would overburden the exemption framework,reduce transaction certainty,and undermine the objective of facilitating efficient corporate restructuring.TheCommitteewasthereforeoftheviewthatsuchsafeguardsare betteraddressedthroughadministrativepracticeandbroaderfiscalpolicyreview rather than embedded statutory conditions.Accordingly,the Committee did not adopt the proposal.

Deloitte&ToucheLLP

36. The stakeholder observed that the current drafting restricts legitimate reorganisations and failstoreflectmodernbusinessstructures.Anchoringtheexemptionon ownershipcontinuity and proportionality will ensure that only genuine internal reorganisations benefit, thereby preserving the tax base while enhancing flexibility and investment attractiveness. Therefore, 2. (i) by the transfer of property—- 3. a)byacompanytoits shareholdersaspartofaninternalreorganisationorby shareholders to a company as consideration for such a reorganisation; or 4. b) ownersaspartofaninternalreorganisation; 5. by a partnership or limited liability partnership (LLP) to its partners as part of an internalreorganisation,orbypartnerstoapartnershiporLLPasconsideration forsuchareorganisation;or 6. d)by a partnership or LLP in a group to another partnership or LLPwithin the part of an internal reorganisation.

providedthat-

1. Theproperty is transferred inproportion to the shareholdingor ownershipinterestoftheshareholdersorGroupcompanies,Partnerships orLLPs,immediatelybeforethetransfer. 2. Il. where the property consists of shares, such shares relate to a direct or indirectsubsidiary,Partnership,LLPoftheentityundertakingthetransfer; and 3. I/l. Thetransferdoesnotresultinachangeintheunderlyingownershipof the property.

CommitteeObservation

The Committee noted the proposal by the stakeholder.However,the Committee further observed that the principle of tax neutrality in genuine reorganisations isalreadyachievedthroughtheinteractionof thedeemed dividendprovisionsunderSection7 and theCapital GainsTaxprovisionsunder theEighthSchedule.Accordingly,codifyingdetailedtransactionalpermutations and ownership tests within this clause may unnecessarily complicate implementation and narrow legitimate restructuring flexibility. The Committee therefore did not adopt the proposal.

WeCareYouthOrganization

• 37.Amend the provision to insert additional safeguards like reporting obligations, a minimum holdingperiod,independentvaluationof transferredassets,and a restrictionwherethere is of the exemptionthrough artificial restructuringand premature disposal of assets,and whereas anchoringthe relief on ownership continuity,transparency,and economicsubstance willensurethatonlygenuineinternalreorganisationsbenefit,therebypreservingthetaxbase while enhancing compliance, investor confidence, and fiscal sustainability.

CommitteeObservations

The Committee noted the proposal by the stakeholder. However, the Committeewasof theviewthatsuchsafeguards are already adequatelyprovided for under the Tax Procedures Act, 2015(including reporting and compliance obligations),the Income Tax Act (including anti-avoidance provisions), and valuationrequirements under existing tax administration practice and applicable valuationstandards.

The Committeefurtherobservedthat introducing additionalstatutory conditions,such asminimumholdingperiods and enhancedbeneficial ownership tests within this clause,would impose unnecessary rigidity,reduce commercial flexibility, and potentially discourage legitimate business reorganisations. Accordingly,the Committee did not adopt the proposal.

OxfamKenya

• 38.The current drafting does not adequately address multi-step avoidance arrangements, conditions.Applying the exemptionuniformly across allasset classesexposes high-risk sectorssuch as landto abusehence thebelowproposed amendment.
• Whereaseries of transactions arepre-arranged and,viewed together,result in an theseries."
• i. Expand andstrengthen the'internal reorganisation'definitionby addingasteptransactiondoctrineclause:
• ii. Enact a GAAR concurrentlywhere the Finance Bill 2026 should include a comprehensive General Anti-Avoidance Rule applicable to all provisions of the IncomeTaxAct,includingthisexemption.
• ili. Amendtheproportionalitybaselineshowing thatshareholdingshouldbe assessedatthedatethatistheearlierof(a)immediatelybeforethetransfer or(b) 12 monthsbefore thecommencementof thereorganisationplan.
• iv. Add an arm'slengthvaluationrequirementwhereall assetstransferredunder thisexemption must bevaluedby a registeredvaluer(per theValuersAct, Cap.532)and thevaluationsubmittedtoKRA.

• Applydifferentiatedtreatmentbyassetclass.Land andhigh-valueimmovable property transfers should be excluded from this exemption (or subject to a reducedrather thanzeroCGTrate)given the existinghighincidenceof landbasedwealth accumulation and avoidance inKenya.

CommitteeObservation

TheCommitteenoted the extensive anti-avoidanceandstructuralproposalsby the stakeholder.However,theCommitteewasoftheviewthatKenya'staxlegal framework already contains a comprehensive anti-avoidance regime,including Section23oftheIncomeTaxActontax avoidancearrangements,aswellas valuation,enforcement,andcompliancemechanismsundertheTaxProceduresAct, 2015.TheCommittee further observed thatintroducing additionalstatutory doctrines such asstep-transaction rules andasset-class-based exclusionswithin this provisionwouldcreatefragmentationintaxlawandundermineuniformapplication of the exemption.

Ernst & Young (LLB) (EY)

39. The stakeholder stated that the paragraph as currently phrased creates ambiguity about what the property is being transferred in exchange for. They noted that there is need to link considerationtotheissuanceofaninterestorclaimon thecompanytherebyresolvingthe ambiguity.They proposed amending the clause to read as follows;-

oron thetransferofproperty tothecompanybythe shareholdersconsiderationforas anInterest or claim-transferonthecompanyto suchshareholderspursuantto thisparagraph,provided that.."

CommitteeObservation

TheCommitteenotedtheconcernraisedbythestakeholderhoweveritrwasofthe view that, the Income Tax Act already contemplates transfer of property in "interest or claim" may create interpretational inconsistencies. Accordingly, the Committee didnotadopttheproposal by thestakeholder

• 40.Additionally,EYnoted that thereis need towiden the scope oftheproposedprovision in the bill to includebothindirect and direct transfers of property to shareholders.They proposed amending the clausetoread asfollows;-

by the transferof propertyby acompanytoits shareholders aspart ofaninternal reorganization, oronthetransferofpropertytothecompanybythe9directandindirectshareholders

• (1)theproperty istransferred to the shareholders inproportion to their shareholding in the companyimmediatelybeforethetransfer;and

• (ll) where the property consists of shares, such shares relate to a subsidiary of the company undertaking the transfer.

For the purposes of the subparagraph 6(2)(i) the term shareholders shall include both direct and indirectshareholders

CommitteeObservation:

The Committee noted theproposal to extend the scope of theprovision to include indirectshareholdersinadditiontodirectshareholders.ItobservesthattheIncome Tax Act already distinguishes legal and beneficial ownership through defined provisions, and the inclusion of indirect shareholders without a clear statutory framework may create enforcement and tracing challenges; therefore, the Committee did not adopt theproposal by the stakeholder.

• 41.Also, EY noted that partnerships of any form, trusts, investment vehicles, cooperative societies, and similar vehicles are widely used inKenya as income-generating and asset-holding structures and frequentlyundertakeinternal restructuringswithnochange inbeneficial withthesubstanceofsuch transactions.EYnotedthatextendingboth theexemptionand artificial corporate conversions, and supports neutrality, certainty and fairness in the applicationofcapitalgainstax.
• (i)"by the transfer of property by a company, partnership, limited liability partnership, trust. cooperativesociety,oranybodycorporate toitsshareholders,partners,members,orequivalent stakeholdersaspartofaninternalreorganisation,oronthetransferofpropertytotheentityby such persons as consideration for the issue of shares, partnership interests,membership units, or equivalentrightspursuanttothisparagraph,providedthat-

42. They proposed amending the clause to read as follows;-

• (1) the property is transferred in proportion to the shareholding, partnership membership interest, unitsorheldimmediatelybeforethetransfer;and
• (ll)wherethepropertyconsists of shares or equivalent interests,suchrelatetoa subsidiary or affliatedbodycorporateundertakingthetransfer."

CommitteeObservation

The Committeenoted the concern thatrestrictingthe exemption to companiesmay createunequaltreatmentbetweendifferentformsofbusinessvehiclessuchas partnerships,trusts,and cooperatives.While the Committee acknowledges the importance of tax neutrality across economic actors, it observes that the current structureoftheIncomeTaxActandtheEighthScheduleisprimarilyentity-specific anddeliberatelydistinguishesbetweencompanies andotherforms ofassociations s wouldrequireacomprehensiveoverhaulofthecapitalgainstaxframeworkandmay haveunintendedfiscal implications.Accordingly,the Committee did notadoptthe proposalby thestakeholder.

Clause3(b)

43. KPMG supported the proposal. They noted it provides clarity on what qualifies as an internal reflectagenuinecommercialrationalebeyondtaxexemption.

OCOB

• 44.The stakeholder observed that the definition of 'internal reorganisation'is minimalist and reliessolelyontheabsenceofa third-partytransfer.Itdoesnotaddressthetreatmentof related parties who may not be shareholders, cross-border reorganisations involving foreign subsidiaries and reorganisations effected through trusts or nominee arrangements.This definitional gap may result in inconsistent application and revenue leakage.

45. They proposed expanding the definition to expressly exclude related-party non-shareholder of 3years post-restructuring,and exclude arrangements structured through trusts or nomineesnotdisclosedtoKRA.

CommitteeObservation

The Committee noted the concerns raised by the OcoB.However,the Committee was of the view that the Income Tax Act (Cap.470), together with theTaxProceduresAct,20l5,alreadyprovidesacomprehensiveframeworkfor addressing residence,beneficial ownership,and anti-avoidance concerns.The Committee furtherobserved that introducingrestrictive statutory conditions such as mandatory post-reorganisation residency requirements and exclusions for create interpretational complexity. Accordingly, the Committee did not adopt the proposal.

Deloitte&ToucheLLP

• 46.Theyobservedthatthecurrentabsenceofdefinitionscreatesambiguityandrelianceon external statutes such as the CompaniesAct.Embedding these definitionswithin the Income Tax Act will enhance legal certainty, promote uniform application, and reduce disputes between taxpayers and the Kenya Revenue Authority. Therefore, amend Paragraph I of the EighthScheduletotheIncomeTaxAct(ITA)toconsolidateall thedefinitionsrelevantto corporatereorganization asfollows:-

"Internal reorganization"means arestructuring of the ownership or control of a company or its assets which does not involve a transfer of property to a third party.

"group" in relation to a body corporate, means the body corporate, any other body subsidiaryofthatholdingcompany.

"Underlying ownership"in relation to a person, means an interest in the person held directly, person not ultimatelyownedbytheindividuals.

"Control" means the capacity to exercise power over the Board of Directors, hold more than half of the voting rights in that other company,or hold more than half of that other company's issuedsharecapital.

"Holding company"is defined as company that (a)controls the composition of that other company's boardof directors,(b)controlsmore thanhalfof the votingrights in that other company, (c) holds more than half of that other company's issued share capital; or (d) is a holding company of a company that is that other company's holding company.

CommitteeObservation

The Committee noted the proposal by the stakeholder. However, the Committee was of the viewthatwhile clarity in interpretation is important, the proposedextensivedefinitionalframeworkisalreadysubstantiallyaddressed through existingprovisionsof the CompaniesAct,2015,and theIncome TaxAct. TheCommittee furtherobservedthatimportingdetailedcorporatelaw definitions into the tax statute may create duplication, rigidity, and potential inconsistencies with evolving corporate law.Accordingly, the Committee did not adopttheproposal.

WeCareYouthOrganization

• 47.Amend the proposal to refine the definition of internal reorganisation by narrowing its scope andintroducingathresholdforchangesinultimatebeneficialownership,sincethecurrent Aligning the definition with principles of clarity, transparency, and international practice will reduce ambiguity, prevent misuse, and ensure that only transactions that do not materially alterownershipqualifyforrelief.

CommitteeObservation

The Committee noted the proposal by the stakeholder. However, the Committee was of theview that introducing ownership thresholds and restrictive definitional limitations may undermine the objective of tax neutrality in genuine internal reorganisations and introduce unnecessary complexity in administration. Accordingly,theCommitteedidnotadopttheproposal.

OxfamKenya

• 48.Clause 3(b) should be amended to adopt a positive and functional definition of "internal framed negatively and relies on undefined concepts, creating ambiguity and interpretive uncertainty.The absence of ownership thresholds andpurpose tests creates room for abuse. Therefore,a clear,substance-based definitionwillenhancelegal certainty,ensureconsistency, andpreventmisuseof theexemption.

CommitteeObservation

The Committee noted the concerns raised by stakeholder. However, the CommitteewasoftheviewthattheIncomeTaxActalreadyincorporates sufficient safeguards against tax avoidance under Section 23,and that the introduction of purpose tests and holding periods within this clause would risk subjective interpretation and reduce certainty in tax administration. The CommitteefurtherobservedthatalignmentwiththeCompaniesActisalready achieved through existing cross-references in corporate and tax law. Accordingly, the Committee did not adopt the proposal.

PWC

Clauses 3(a) and 3(b)

• 49.Amend the clauses because the current corporate-centric drafting excludes partnerships, trusts,andLLPsdespitetheirincreasingcommercialrelevance,whileundefinedconceptssuch as"thirdparty"andoverlybroadphrases like"restructuringof assets"create ambiguity and overreach,andprovidedthattherevisedprovisionsadoptasubstance-over-formapproach anchored on continuity of economic ownership, the following proposed amendments will alignthelawwithmodern business structures,improve clarity,andprevent unintended tax exposure.
• (A) Insert the following definitions inParagraph I(l) of the EighthSchedule:-

"interest holders"means,as the case may be, the shareholders of a company, the partners ofapartnership orlimited liabilitypartnership,thebeneficiaries ofatrust,or themembers ofanyotherbodyofpersons;

• (B) Amend the proposed Paragraph 6(2)(i) of the Eighth Schedule to read as follows: "(i)by the transfer ofpropertyby apersonundertakingareorganisation toits interest holders,orby theinterestholders to suchperson,aspart of aninternal reorganisation, providedthat—— (1) theproperty is transferred to the interest holders in proportion to theirrespective interestsimmediatelybeforethetransfer;and

• (Ill)where theproperty consists of shares or comparableinterests,such shares or interestsrelatetoacompany,partnership,limitedliabilitypartnership,trustor otherbodyof persons inwhich theperson undertaking thetransfercontrols."
• "(2A)For the purposes of this Schedule,'internal reorganisation'means any transaction orseriesoftransactionsthatresultsinachangeinthemannerinwhichthepropertyofa person undertaking a reorganisation,or the shares or interests held in or by suchperson, areheld amongthatperson anditsinterestholders,andincludeswithout limitation——
• (a)the distribution of property,including shares or comparable interests,by a person undertakingareorganisation toitsinterestholders;
• (b)thetransferofpropertyby interest holders toapersonundertaking reorganisationinexchangeforshares,interestsorotherconsideration;
• (c)the consolidation,division orrearrangement ofproperty,sharesorinterests betweenapersonundertakingareorganisationanditsinterestholdersprovided that the transaction does not involve a transfer of property to any person who was notaninterestholderofthepersonundertakingthereorganisationimmediately beforethetransaction."

CommitteeObservation

TheCommittee noted the comprehensive restructuring proposalsby the stakeholder.TheCommitteewasoftheviewthattheIncomeTaxAct,when readtogetherwiththeEighthScheduleandrelevantprovisionsonchargeable income and capital gains,already provides sufficient coverage for qualifying reorganisations.TheCommitteefurtherobserved thatintroducingexpanded scopeoftheexemptionandcreateinterpretationalchallengesinadministration. Therefore,the Committee did not adopt the proposal.

Ernst&Young

50. The stakeholder noted that many corporate groups operate through complex multi-layered ownership structures comprisinga mixof companies,partnerships of anyform,limited liability partnerships (LLPs), limited liability companies (LLCs), trusts, cooperative societies and other entities.Internalreorganisationswithinsuchgroupsareoftenundertakenforoperational, ownership.Limitingrelieftocompaniesalonemaythereforeresultinotherwisetax-neutral grouprestructurings attracting capitalgains tax solelydue to thedifference in the body corporates usedwithin the same corporate group. 2. 51.Theyproposed amending the definition of"internal reorganisation"toread asfollows:

"For the purposes of this subparagraph,reorganisation means internal a restructuring of the ownershiporcontrolofacompany,limitedliabilitypartnership,trust,cooperativesocietyorany body corporate, or its assets, which does not involve a transfer of property to a third party."

CommitteeObservation

The Committee noted the comprehensive restructuring proposals by the stakeholder.The Committeewas of theview that theIncome Tax Act,when readtogetherwiththeEighthScheduleandrelevantprovisionsonchargeable income and capital gains, already provides sufficient coverage for qualifying reorganisations.The Committee further observed that introducing expanded scopeoftheexemptionandcreateinterpretationalchallengesin administration.Therefore,the Committee did not adopt the proposal.

NewProposals

• 52.Bowmansobserved thatthereisa need toprovidefor a similarprovisionintheStampDuty Act. They proposed amending the existing stamp duty exemption so that it also covers the transferofpropertybyshareholders tothecompany asconsiderationinthe same internal reorganisation, subject to the same conditions and safeguards. That would ensure consistency and fully give effect to thepolicy of facilitating tax-efficient internal reorganisations.

CommitteeObservation

The Committee noted the proposal by the stakeholder. However, the Committee was of the view that stamp dutyis governed under a distinct legal andfiscalframeworkundertheStampDutyAct(Cap.480),andanyamendments to exemptions therein should be considered within that specific statutory context.

PWC

NewProvision

53. Amend the existing Paragraph 13 (c) of the Eighth Schedule by deleting the words "which has existedforatleasttwenty-fourmonths"toreadasfollows: 2. "(c)an internal restructuring within agroup which does not involve a transfer of 3. 54.This proposal is to eliminate reliance on the undefined concept of "third party",since the time-based condition imposes an arbitrary and economically unjustifiable barrier to genuine post-acquisition restructuring,and whereas the existing clawback mechanism under Paragraph 8(4A) already safeguards revenue by ensuring deferred gains are taxed upon subsequent disposal,removing the restriction will facilitate business integration,improve cash flowefficiency,andenhanceKenya's investment attractiveness,whilealigningtheprovision with the Bill's broader objective of ensuring tax neutrality for internal reorganisations that do notalterbeneficialownership.

CommitteeObservation

The Committee noted the proposal by the stakeholder. However, the CommitteewasoftheviewthattheexistingframeworkundertheEighth Schedule,including clawbackprovisions under Paragraph8(4A),already provides adequatesafeguardstopreservethetaxbasewhileallowingdeferredtaxationon qualifying transactions.The Committee further observed that the proposed removalofthe time-based restrictioncouldincreaseexposuretotaxplanning risks in short-term restructuring arrangements. Therefore, the Committee did not adopt the proposal.

WeCareYouthOrganization

NewProvision

55. The stakeholder proposed a new provision should be introduced to clarify that the exemption revenueandmustbesubjecttooversight.Enhancedtransparencyandintegrationwith existinganti-avoidanceframeworkswillstrengthenaccountability,safeguardfiscal sharing.

CommitteeObservation:

The Committee noted the proposal by the stakeholder. However, the Committeewasoftheviewthatthe applicationoftheGeneralAnti-Avoidance RuleunderSection23oftheIncomeTaxActisalreadyofgeneralapplicationand applies to all provisions of theActwithoutrequiringrepetition inspecificclauses. TheCommitteefurtherobservedthatdisclosureandreportingobligationsare adequatelyprovided for under the Tax Procedures Act,2015.Accordingly,the Committeedidnotadopttheproposal.

General Submissions

EarnestAndAssociatesLLP

56. The stakeholder supported the Income Tax (Amendment) Bill, 2026, since the proposed amendmentspromoteconsistencywithinKenya'staxframeworkbyaligningtheIncomeTax Act with Section I17(l)(r) of the Stamp Duty Act (Kenya),which similarly provides for exemption of transfers undertaken as part of internal reorganisations.Such harmonisation reduces interpretive ambiguity, enhances predictability,and minimizes compliance disputes, theBillwillfacilitatemoreefficientandorderlycorporaterestructuring. 2. 57.Thestakeholderfurthernotedthattheamendmentsplayacriticalroleinresolvinglong often result in idle or underutilised land, prolonged litigation, and stalled corporate decision-

Report of the Departmental Committee on Finance and National Planning on its Consideration of TheIncomeTax(Amendment)Bill(NationalAssemblyBillNo.20Of2026)

unlocking the economic value of such assets, the reforms will support improved utilisation andgovernanceoutcomes.

• 58.Inaddition,thestakeholderobservedthattheBillenablesthereversionof landtoindividual shareholders,sinceindividualownershipallowsformoreefficientandtimelydecision-making regarding the use,development,or disposal of land, and whereas corporate ownership structures have insome cases contributedtoinactivity and inefficiency,the proposed framework will enhance the productivity of land assets and stimulate investment.

59. The stakeholder also supported the exemption of such transfers from dividend taxation, since imposing dividend taxonnon-cashreorganisationswouldcompel shareholders toliquidate assets, incur debt, or utilise limited liquidity to meet tax obligations, and whereas this would undermine the objective of preserving assetvalue during restructuring,the exemption availableforproductive use.

KenyaInstituteofSuppliesManagement

60. The stakeholder supported the proposed exemption of internal reorganisations from Capital needtopromoteefficientcorporatereorganisationframeworks.Suchexemptions are supportiveofeconomicactivity. 61. The stakeholder, however, recommended that the Bill be amended to incorporate anti-abuse safeguards,sincethe absenceof clearguidelinesonwhatconstitutes aninternal reorganisation providing a precise and legally robust definition will enhance clarity, prevent misuse, and ensurethatonlygenuinerestructuringtransactionsbenefitfromtheexemption. 3. 62.The institute further suggested the introduction of a claw-back mechanism,since tax exemptionsgrantedatthepointofreorganisationmaybeabusedwhereassetsare subsequentlydisposedoftothirdpartieswithin a shortperiod,andwhereas reversingthe exemptioninsuchcaseswillprotectthetaxbaseandensurethatthereliefisnotusedto facilitate disguised disposals. In addition, the stakeholder noted that the Bill require asset transferstobeconductedatfairmarketvaluebasedonindependentprofessionalvaluation, sinceundervaluationor overvaluationofassetsmaydistort taxoutcomesandcreate opportunitiesforabuse. 63. The stakeholder also recommended that disposal processes be guided by transparent and competitive principles, since the absence of structured processes may undermine fairness and value formoney,andwhereas aligning such transactionswithprocurement principles will enhance accountability, equity, and efficiency in the handling of assets.

CommitteeObservations

The Committeenoted the supportexpressed by thestakeholder.However,the CommitteewasoftheviewthattheIncomeTaxAct(Cap.470)andtheEighth Schedulealreadyprovideasufficientlegalframeworkfordeterminingchargeable gains,andthetax treatment of qualifying internal reorganizations.The Committee further observed that existing provisions under the Tax Procedures Act,2015, together with general anti-avoidance provisions under Section 23of theIncome TaxAct,adequately address concerns relating totax avoidance, includingdividendstrippingandartificialrestructuring.

Withregard toproposalsfor claw-backmechanisms,mandatoryindependent valuation,and procurement-aligned disposal processes,the Committee was of theview thatintroducing suchproceduraland valuation-specificrequirements withinthisexemptionclausewouldovercomplicatetax administrationand potentially underminetheobjectiveoffacilitatingefficientcorporate restructuring..Therefore,the Committee did not adopt the proposed additional safeguards.

Oxfam Kenya

NewProvision

• 64.Introduce a new proposal to establish countervailing measures including a high-net-worth aminimumwealth-basedcontribution.TheBillintroduces atax exemptionwithout corresponding revenue measures, thereby shifting the burden to other taxpayers,while offsets will enhance equity, strengthen domestic resource mobilisation, and safeguard fiscal sustainability.

CommitteeObservations

The Committee noted the proposal by the stakeholder.However, the Committee wasoftheviewthattheFinanceBilloperateswithin atargetedpolicyframework and that the introduction of new tax surcharges or wealth-based levies within this provision would amount to a broader tax policy shift that extends beyond the scope oftheamendmentunderconsideration.

The Committee further observed that matters relating to progressive taxation and wealth redistribution are appropriately addressed through comprehensive fiscal policyandannualbudgetaryprocessesratherthanbeingembeddedinspecific exemption clauses.Accordingly,the Committee did not adopt the proposal.

WestminsterConsultingLLP NewProvision

• 65.Amend Section 15 to empower the Commissioner to prescribe or apply allowable expense categories of transactions. The current reliance on electronic invoicing systems may result in the disallowance of genuine business expenses. This occurs where documentation does not fully comply with system requirements. Introducing safe-harbour mechanisms will ensure that taxation reflects actual economic activity.It will reduce disputes,ease compliance burdens, andimprove administrative efficiencywhilemaintainingrevenue integrity.

CommitteeObservation

The Committee noted the proposal by the stakeholder.However,the Committee wasoftheviewthatSectionI5oftheIncomeTaxAct,togetherwiththeTax ProceduresAct,2015,alreadyprovidessufficientlegalbasisfor the Commissioner toassessallowabledeductionsbasedonactualexpenditureandsupporting documentation.

The Committee further observed that introducing sector-specific safe-harbour ratios or presumptive margins within the statute may undermine the principle of taxationbasedonactualincomeandexpenditure,andcouldcreateinconsistencies in tax treatment acrosssectors.The Committee alsonoted thatadministrative guidanceandpracticenotesissuedbytheKenyaRevenueAuthorityarebettersuited Accordingly,the Committee did not adopt theproposal.

CHAPTERFOUR

4COMMITTEEOBSERVATIONS

66.TheCommitteemadethefollowingobservations:

I)ObjectoftheBill

TheBillseekstoamendtheIncomeTaxActtoprovidefortheexemptionofcapitalgains tax in the transfer of property by a company to its shareholders as part of an internal s considerationforthe transfer.

ScheduletotheIncomeTaxActtoprovidethattransfersofpropertybetweenacompany Gains Tax, provided certain conditions are met. These conditions include that the property must be distributed in proportion to the shareholders' existing shareholding immediatelybeforethetransfer,andwheresharesareinvolved,theymustrelatetoa subsidiary of the company undertaking the reorganisation.

2)SupportfortheBill

Themajorityofthestakeholderswhoeithermadeoralsubmissionsorsubmitted clarify the intention of the amendments, provide necessary safeguards,or expand its scope.TheCommittee noted theproposalsbutwas of theview thatadditionalproposals couldbeaddressedthroughadifferentBill,preferablyinaFinanceBill orataxBill.

CHAPTERFIVE

5.COMMITTEERECOMMENDATION

67.The Committee,having considered the Income Tax(Amendment) Bill (National Assembly Bill No. 20 of 2026)/recommends that the House approves theBill with amendments.

SIGNED...

.DATE

HON.FCPAKURIAKIMANI,CBS,MP CHAIRPERSON DEPARTMENTALCOMMITTEEONFINANCEANDNATIONALPLANNING

CHAPTERSIX

6.0.SCHEDULEOFAMENDMENTS

Income Tax(Amendment) Bill (National Assembly Bill No. 20 of 2026)Committee proposes the followingamendment:

CLAUSEI

THAT,clause/of the Billbe amended byinsertingthe words"and shall come intooperationupon publication"at theendoftheclause.

Justification

The proposed amendment seeks to provide for the commencement of the provisions of the Act upon publication so as to correct an anomaly occasioned after passage of the Finance Act, 2025. The amendment seeks to align the provisions to amendments passed in the Finance Act, 2025.

THENATIONALASSEMBLY THIRTEENTHPARLIAMENT-FIFTHSESSION-2026

DEPARTMENTALCOMMITTEEONFINANCEANDNATIONALPLANNING. ADOPTIONLIST

REPORTONTHEINCOMETAX(AMENDMENT)BILL(NATIONALASSEMBLYBILLNO. 20 OF 2026)

We, the Members of the Departmental Committee on Finance and National Planning have pursuant to Standing Order 199, adopted this Report and affix our signatures to affirm our approval and confirm its accuracy,validity and authenticity today, Tuesday,28thApril2026.

| S/NO. | NAME | SIGNATURE | |---------|----------------------------------------------------------|-------------| | 1. | HON.FCPAKURIAKIMANI,CBS,MP- CHAIRPERSON | | | 2. | HON.FCPA(AMB).BENJAMINKIPKIRUILANGAT, MP-VICECHAIRPERSON | | | 3. | HON.KALUMA PETEROPONDO,CBS,MP | | | 4. | HON.GEORGESUNKUYIARISA,MP | | | 5. | HON.(FCPA)JOSEPHMAERO OYULA,OGW,MP | | | 6. | HON.ANDREWADIPO OKUOME,MP | | | 7. | HON.DAVIDMWALIKAMBONI,MP | | | 8. | HON.CHIFOROMODOMANGALEMUNGA,MP | | | 9. | HON.MAINABETTYNJERI,MP | | | 10. | HON. (CPA)JULIUSKIPLETTING RUTTO,MP | | | 11. | HON.PAULKIBICHIY BIEGO,MP | | | 12. | HON. UMUL KER SHEIKH KASSIM, MP | | | 13. | HON.DR.SHADRACKMWITIITHINJI,MP | | | 14. | HON.DR.JOHNARIKONAMOIT,MP | | | 15. | HON.MOHAMEDSOUDMACHELE,MP | |