*Experience gained prior to joining Bowmans

A selection of Patience’s experience includes:

Tax dispute resolution experience

• Advising clients on the nature and extent of any identified exposures and helped them make voluntary disclosures to the KRA in order to avert disputes with KRA.
• Assisting clients in responding to any KRA queries raised on their tax affairs, as well as responding to demand letters raised by the KRA.
• Assisting clients in preparing and lodging objections challenging KRA’s assessments.
• Lodging Judicial Review Applications in Court challenging the unlawful and unprocedural exercise of powers by the KRA.
• Supported clients undergoing audits by the revenue authority to resolve audit issues and avert the raising of tax assessments.
• Acted for and defended clients at the Tax Appeals Tribunal where tax disputes arise between clients and the Revenue Authority and have been carried forward to the Tribunal.
• Represented client interests in negotiations with the revenue authority in the Alternative Dispute Resolution process.
• Advised clients with respect to case settlement strategies.
• Reviewed objections to assessments and issued Objection Decisions communicating the Commissioner’s decision. *

Tax advisory experience

• Assisting clients with tax reviews to ensure compliance. *
• Providing tax advice and opinions to clients with regards to the tax status of their present transactions and how to structure transactions in an optimal way.
• Conducted numerous tax health check exercises for clients across all sectors, and assisted them develop internal measures to minimize or eliminate the risk of future exposures.
• Ad hoc tax advice – responding to specific tax queries raised by clients on various tax matters such as completion of tax questionnaires and email queries.

Select experience

Tax dispute resolution

• Mawingu Networks Limited with respect to an excise duty dispute at the Tax Appeals Tribunal. Bowmans was also engaged for assistance with an application for acceptance of a late objection which was successful.
• Assisted a property development company in objecting to a Pay As You Earn assessment in relation to payments made to human resource outsourcing company.
• Successfully represented a leading manufacturer of specialist chemicals to the construction industry in negotiations with KRA in the Alternative Dispute Resolution process and obtained a favorable settlement proposal.

General tax advice matters

• Advising on tax exemptions for aid funded projects
• Advised on Kenyan taxes applicable to cross border transactions, the Kenyan Double Tax Treaty network and structuring, particularly with regards to holding company jurisdictions.
• Advised a conversancy on the tax implications of granting occupation rights.
• Advised on the tax implications on the sale of carbon credits.
• Advised on the tax optimal structure of financing for various clients.

Employee matters

• Ad hoc tax advisory on employment matters – responding to specific tax queries raised by clients on various tax matters such as completion of tax questionnaires and email queries.
• Advised a tech-enabled recycling company on the tax implications of the ESOP guidelines.
• Assisted in preparing a presentation to a retailer of auto parts and accessories on the tax implications of the various options available in relation to ESOP.
• Advised a financial services provider on the tax implications of the ESOP options.

Tax due diligence

• Assisted in conducting a tax due diligence on a company distributing pharmaceutical products in Kenya for a healthcare company based in United Arab Emirates.
• Assisting in a tax due diligence on a property holding company for a religious organization.