Patience Mbugua

Patience Mbugua

Senior Associate
Nairobi, Kenya: Coulson Harney LLP
T: +254 +254 20 503 160020 289 9000
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Patience is a Senior Associate in our Nairobi office and a member of the Tax department.

She is an Advocate of the High Court of Kenya and a Certified Public Accountant, Kenya (CPAK) with over ten years’ experience in providing a wide array of tax services.

Patience has extensive experience in tax dispute resolution having successfully assisted clients in preventing and resolving disputes with Kenya Revenue Authority (KRA). She has been involved in providing services throughout the dispute resolution cycle including assisting with voluntary tax disclosures, KRA audit support, objections to assessments, appeals to objection decisions, settlement negotiations and litigation.

In addition to tax dispute resolution, she has also built a formidable body of technical knowledge of tax compliance matters and experience in a range of different industries including insurance, hospitality, infrastructure development, energy, telecommunication, consumer, state corporations and not for profit organizations. She has provided services on a wide array of tax matters such as general tax compliance, tax reporting, tax consulting, tax due diligence and obtaining tax rulings.

Prior to joining Bowmans, she worked with the Kenya revenue Authority and in PricewaterhouseCoopers (PwC) Kenya.

Specialist Services

Relevant Experience

*Experience gained prior to joining Bowmans

A selection of Patience’s experience includes:

Tax dispute resolution experience

  • Advising clients on the nature and extent of any identified exposures and helped them make voluntary disclosures to the KRA in order to avert disputes with KRA.
  • Assisting clients in responding to any KRA queries raised on their tax affairs, as well as responding to demand letters raised by the KRA.
  • Assisting clients in preparing and lodging objections challenging KRA’s assessments.
  • Lodging Judicial Review Applications in Court challenging the unlawful and unprocedural exercise of powers by the KRA.
  • Supported clients undergoing audits by the revenue authority to resolve audit issues and avert the raising of tax assessments.
  • Acted for and defended clients at the Tax Appeals Tribunal where tax disputes arise between clients and the Revenue Authority and have been carried forward to the Tribunal.
  • Represented client interests in negotiations with the revenue authority in the Alternative Dispute Resolution process.
  • Advised clients with respect to case settlement strategies.
  • Reviewed objections to assessments and issued Objection Decisions communicating the Commissioner’s decision. *

Tax advisory experience

  • Assisting clients with tax reviews to ensure compliance. *
  • Providing tax advice and opinions to clients with regards to the tax status of their present transactions and how to structure transactions in an optimal way.
  • Conducted numerous tax health check exercises for clients across all sectors, and assisted them develop internal measures to minimize or eliminate the risk of future exposures.
  • Ad hoc tax advice – responding to specific tax queries raised by clients on various tax matters such as completion of tax questionnaires and email queries.

Select experience

Tax dispute resolution

  • Mawingu Networks Limited with respect to an excise duty dispute at the Tax Appeals Tribunal. Bowmans was also engaged for assistance with an application for acceptance of a late objection which was successful.
  • Assisted a property development company in objecting to a Pay As You Earn assessment in relation to payments made to human resource outsourcing company.
  • Successfully represented a leading manufacturer of specialist chemicals to the construction industry in negotiations with KRA in the Alternative Dispute Resolution process and obtained a favorable settlement proposal.

General tax advice matters

  • Advising on tax exemptions for aid funded projects
  • Advised on Kenyan taxes applicable to cross border transactions, the Kenyan Double Tax Treaty network and structuring, particularly with regards to holding company jurisdictions.
  • Advised a conversancy on the tax implications of granting occupation rights.
  • Advised on the tax implications on the sale of carbon credits.
  • Advised on the tax optimal structure of financing for various clients.

Employee matters

  • Ad hoc tax advisory on employment matters – responding to specific tax queries raised by clients on various tax matters such as completion of tax questionnaires and email queries.
  • Advised a tech-enabled recycling company on the tax implications of the ESOP guidelines.
  • Assisted in preparing a presentation to a retailer of auto parts and accessories on the tax implications of the various options available in relation to ESOP.
  • Advised a financial services provider on the tax implications of the ESOP options.

Tax due diligence

  • Assisted in conducting a tax due diligence on a company distributing pharmaceutical products in Kenya for a healthcare company based in United Arab Emirates.
  • Assisting in a tax due diligence on a property holding company for a religious organization.

Publications & Insights