On 23 February 2024, the Tax Appeals Tribunal (TAT or Tribunal) in Kenya issued a ruling (M-Kopa LLC v. Kenya Revenue Authority,
Tax Appeal No. 65 of 2023) in favor of a digital financial service provider, affirming that for nonresident companies the place of
effective management (POEM) for tax-residency purposes, is determined based on the location where the board of directors met
and made key management and commercial decisions necessary for the entity to conduct business. This decision also
emphasized that the location of the majority of directors is vital in determining the POEM.