Sam has advised:

• A money remittance company with respect to taxes applicable on money remittance services and advisory services on a dispute with the revenue authority on the interpretation of provisions of the Excise Duty Act relating to applicability of excise duty on money remittance services.
• A multinational based in the United States on the applicability of digital services tax, and VAT on the digital marketplace on digital services provided in Kenya.
• M-Kopa LLC on a tax dispute on whether management and control of the said entity was exercised in Kenya.
• A multinational client in the confectionary business based in the UK on the implications of a smart invoicing scheme between a distributor in the Middle East and a Kenyan distributor particularly with respect to the falsifying of invoice amounts for purpose of customs declarations.
• Promasidor Kenya Limited on the effect of advance tariff rulings issued by the Kenya Revenue Authority and handling the disputes arising from the advance tariff rulings at the Tax Appeals Tribunal and the High Court.
• Various entities implementing renewable energy projects on tax exemptions available in under Kenyan tax legislation and the process of obtaining the applicable exemptions.
• Various companies on employment matters such as secondment of employees to Kenya, the tax implications of the said secondments and whether these trigger a permanent establishment risk in Kenya.
• Various companies on tax incentives in the Special Economic Zones (SEZ) and the process of applying to obtain licencing as an SEZ entity.
• Various entities on the implications of indirect capital gains tax and whether the relevant transactions are subject to indirect capital gains tax.
• Various entities on tax implications arising from the sale of carbon credits.
• An offshore and onshore contractor with respect to a transfer pricing audit and corporate income tax refund claim. The matter involved advising on the tax implications of structuring an engineering, procurement and construction contract (EPCM) as an offshore and onshore contract.
• Africa Oil Kenya Limited with respect to a tax dispute at the Tax Appeals Tribunal involving income tax and VAT matters.
• A telecommunications company with respect to certain excise duty matters and assistance with the renewal of income tax exemption for MPESA Foundation.
• Majid Al Futtaim with respect to a tax dispute pertaining to certain customs and VAT Auto Assessment matters.
• I&M Bank Limited with respect to an appeal from a decision of the Tax Appeals Tribunal on deductibility of bad and doubtful debts for income tax purposes.
• Mobius Motors Kenya Limited with respect to an appeal to the High Court from a Tax Appeal Tribunal Decision in relation to withholding tax matters.
• Netflix Inc. and AirBnB.com Inc. on the tax implications of digital services tax and VAT on transactions conducted on the digital marketplace on their businesses in Kenya.
• com Inc. in respect of the applicability of digital services tax and VAT, the tax implications of the establishment of PoP sites and network facilities in Kenya covering among others permanent establishment risk, the tax implications in respect of intercompany transactions, customs procedures and the process on importation of goods and dealings with suppliers.
• Various conservancies in Kenya on tax implications on their business models including on wildlife conservation easements.
• Google on an ongoing basis with respect to the various tax matters that impact its activities in Kenya.
• Uber in respect of the tax implications of operation of the Uber Platform in Kenya, the tax implications of introduction of the UberEATS product in Kenya and the proposed provisions in the Finance Bill 2019 on taxation of companies operating a digital platform in Kenya.
• A car manufacturer with respect to an appeal to the High Court from a Tax Appeal Tribunal Decision in relation to withholding tax matters.
• A telecommunications company with respect to a customs dispute at the Tax Appeals Tribunal, including acting for the company with regard to the issue of agency notices by the Kenya Revenue Authority.