Samuel’s key area is transfer pricing and international tax. He has been involved in transfer pricing documentation and defence for multinational enterprises in Kenya, Uganda, Tanzania and Rwanda for the past 6 years. He has advised multinational enterprises on localization of their global transfer pricing policies in line with the local jurisdictions’ transfer pricing regulations as well as structuring of operations to ensure tax efficiency and compliance.
Other practice areas span across the major tax areas: tax structuring & restructuring, mergers and acquisitions, business setups and structuring, offshore entity setups, tax risk and opportunities assessments (tax compliance review), due diligence, tax computations, applications for waivers for penalties and interests, tax authorities audit assistance involving in-depth examinations of tax assessments and raising objections, tax trainings, and Value Added Tax (VAT) refund audits. He has experience working with major players in industries in the countries that he has worked in. These include shipping and logistics, manufacturing, real estate, energy, oil and gas, tourism, banking, telecommunication, agriculture among others.
University of Nairobi – Bachelor of Arts
Strathmore University – Association of Chartered Certified Accountants (“ACCA”)
Transfer pricing & Principles of International Taxation certificates from the Chartered Institute of Taxation.
January 2018 – Present: Director, Taxwise Africa Consulting LLP
January 2015 – December 2017: Manager, Taxwise Africa Consulting LLP
January 2014 – December 2014: Consultant, Taxwise Africa Consulting LLP
January 2013 – December 2013 : Senior Tax Analyst, Taxwise Consulting Limited
January 2012 – December 2012 : Tax Analyst, PKF Taxation Services
- Defended a client acting as a buying agent for its parent company as well as being a distributor on own account that resulted in the vacating of a 50 million dollars transfer pricing demand.
- Defended a shipping agent in Kenya that resulted in the vacating of an 8 million dollars VAT demand and the dropping of a transfer pricing audit.
- Tax structuring for various taxpayers undertaking various projects and investments in Kenya. The structuring undertaken cover transfer pricing, onshore & offshore structures, operations structuring to ensure tax efficiency, equity versus debt financing, permanent establishments implications and various tax savings exercises under corporation tax, withholding tax, capital gains tax, PAYE, VAT and Customs duties.
- Tax risk and opportunity assessment for various clients in Kenya, Uganda, Rwanda & Tanzania.
- Undertaken various transfer pricing assignments under documentation, implementation and defending the TP arrangements of various companies in Kenya, Uganda, Tanzania, Mauritius and Rwanda. His involvement entailed documentation, review of the transfer documentation to be presented to the revenue authorities, advocating for the adoption of the transfer pricing methodologies by revenue authority and technical review and negotiations on the transfer pricing assessments/adjustments by revenue authorities.
- Represented a local manufacturer of sanitary wear that led to the exemption of raw materials for the manufacture of sanitary pads in the Finance Act 2016 under the First Schedule of the VAT Act 2013.
- Tax trainings across the East African region; and
- Involved actively in thought leadership through being a regular author for Taxwise, Bloomberg and Tax Notes International.