Section 65 of the Tax Procedures Act, 2015 provides that a taxpayer may apply to the Commissioner for a private ruling which shall set out the Commissioner's interpretation of a tax law in relation to a transaction entered into, or proposed to be entered into, by the taxpayer.

The following guideline will govern the applications for private rulings under this section:

1. The application should be made in writing and shall include the following:-
2. The name and Personal Identification Number (PIN) of the taxpayer to whom the private ruling sought relates.
3. The relevant details of the transaction(s) entered into or proposed to be entered into by the person. The application should not relate to a hypothetical scenario.
4. The precise question on which the Commissioner’s interpretation is required.
5. The relevant tax law(s) and a full statement by the applicant, setting out their interpretation of the tax law(s) in relation to the transaction.
6. All relevant supporting documents of the transaction to which the application relates.
7. The application should not relate to a matter that is the subject of a tax audit, is under objection or where a notice of assessment has been served to the applicant.
8. Applications for private rulings should be addressed to: The Deputy Commissioner, Policy & Tax Advisory and delivered to Times Tower 19^th Floor or emailed to DCP&TA@kra.go.ke.
9. Applicants should provide their contact details (telephone/email) in the application.

Commissioner for Domestic Taxes