Lewa Wildlife Conservancy L1mited

a) Whether the Respondent's letter dated 16th February, 2001 created
legitimate expectation on the Appellant that park entry fees was
not chargeable to tax

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Kingdom Kenya 01 Limited

i) Whether withholding tax and reverse VAT ought to have been charged on Guest recognition expenses

Whether VAT should have been paid on transportation of guests

Whether input VAT should be restricted where exempt sales
Exceeding total sales

iv) Whether verse VAT should be paid on account of a time
barred input VAT

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Kibuwa Enterprises

On 16th June, 2016, the parties agreed by consent to dispose of the Appeal by way of
written submissions with the Appellant being required to file its written submissions
within seven
(7) The Appellant complied with the order by filing their written
submissions on 22" June, 2016.

2. The Respondent was therefore required to file and serve their written submissions by
29th June, 2016.

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Kenya Wildlife Service

The Tribunal having demined that there is a service, the next
issue for determination would" be whether and if so, when did the
service become taxable?

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Kenindia Assurance Company Limited

The issue for determination on the basis of both the oral and written submissions
on record before the Tribunal is whether the taxation of the capitalized funds
amounted to double taxation and offended the provisions of Article 47 of the
Constitution of Kenya, 2010 as regards the Appellant's entitlement to a fair, legal
and reasonable administrative action on the part of the Respondent.

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