My view on registration of agents, section 3
The regulations indicate part (d) indicate persons qualifying to act as agents are holders of any other qualification, that the commissioner considers relevant. This opens a lacuna and waters down the whole essence of qualification, any other qualification means any other and that opens the field and gives the commissioner very wide powers
Secondly, also qualifying for registration are former employees of KRA. This compromises independence between current KRA employees and their former bosses
Thirdly, who is a qualified tax professional, the duties as per regulation are skewed towards filing returns not litigation matters. Find the practice in blue chip companies world over, who handles their tax matters particularly filing returns

11. Offences: Are there penalties to these offences or it is left for the person discovering the offences to determine the penalties imposed to such offenders?