Comments to answers

Why is a Kenyan Company disbursing payments to the non residents on behalf of a non resident company? The reason would be that the Kenyan company is managing the European companies affairs within the Kenyan soil. Then the Kenyan company contacts other African companies to perform these services. This then would satisfy the provisions of Income Tax Act Section 3(1).
Secondly, the Kenyan company is acting as an agent of the European companies. By the fact that the beneficiaries are African Companies and thus are not resident, failure to withhold tax from the given that the income is derived from Kenya would cause tax erosion. If the Kenyan company falls under a dependent agency as stated in the Act, the local company would thus be required to withhold the tax.

There are services that non resident companies are mandated to pay namely air transport, charter services where the persons or cargo embarks from Kenya. These are charged at the gross income level. The only exception to this is the case of transshipment.