F. M. Mac Haria L1mited

Whether the additional VAT estimated at 20 405 298/= including penalty and interest is correct

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Evamar Investments L1mited

I) Whether sale of developed real estate property falls under business
income for income tax purposes under See. 3(2)(a).

ii) Whether interest income is a separate source of income for tax
purposes.

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Ericsson(K) Limited

a) Whether the supply made by the appellant to TKL and EWKL
shall be treated as supply of taxable services rendered to local
parties or export of services as invoiced to EAB.
b) Whether the amount received from EAB shall be considered as a
loan or payment
in lieu of dues from TKL and EWKL and shall be considered as
taxable income.

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Diakonie Emergency Aid Appellant

What was the relationship between the Appellant, DEA-PHC based in
South Sudan and DBG based in Somalia? Where are these institutions
registered?
2. What is a Permanent Establishment? Whether the Appellant is a
Permanent Establishment as provided for under Section 2 and 3 (2)(a)
(ii) of the Income Tax Act Cap 470 in relation to mode and manner
Judgement: Tax Appeals No. 46 of2015 Page 2
of operations between DEA Nairobi, DEA- PHC based In South
Sudan and DBG based in Somalia?

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Delmonte Kenya Limited

i) When foreign exchange differences are realized.

ii) Whether foreign exchange losses arising on conversion of debt to
equity is-an allowable expense.

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