VAT Special Table in Kenya: ETIMS Compliance, Onboarding, Removal & Applicable Tax Laws

The VAT (Value Added Tax) Special Table has become a key focus area in Kenya’s tax administration following the rollout of the Electronic Tax Invoice Management System (ETIMS). Many businesses are asking: What is the VAT Special Table? Who can be onboarded? How can one be removed? And what tax laws apply?

Let’s break it down.

What is the VAT Special Table?

The VAT Special Table is essentially a compliance list maintained by the Kenya Revenue Authority (KRA). It contains taxpayers who, due to compliance concerns or discrepancies, are subjected to stricter VAT scrutiny. The table is directly tied to the ETIMS system, which ensures that all VAT invoices issued and claimed for input tax are verified electronically.

Being listed on the VAT Special Table often means KRA has flagged your business for one or more of the following reasons:

• Persistent non-compliance with VAT obligations

• Mismatch between sales declared and invoices issued

• Suspicion of engaging in fraudulent claims or tax evasion

• Failure to properly onboard onto ETIMS as required

  Who Can Be Onboarded to the VAT Special Table?

  KRA onboards taxpayers onto the Special Table based on compliance risk assessments. Typically, the following categories are affected:

  1. VAT-registered taxpayers who fail to adopt ETIMS – Non-compliance with the requirement to issue and transmit electronic tax invoices.

  2. Businesses with questionable input VAT claims – Entities that routinely submit VAT returns with unverifiable purchase invoices.

  3. High-risk sectors – Certain industries, such as imports and wholesale trade, where VAT fraud has historically been common.

  4. Taxpayers flagged during audits or data analytics – If system checks show inconsistencies in VAT declarations versus actual business transactions.

     How to Be Removed from the VAT Special Table

     Being placed on the VAT Special Table is not permanent. Taxpayers can be removed by demonstrating compliance through:

     1. Full ETIMS Compliance

        • Onboard onto ETIMS by installing and using the approved invoicing software/hardware.

        • Ensure every transaction is properly captured and transmitted to KRA.

     2. Rectification of Tax Returns

        • Amend returns where discrepancies exist.

        • Provide supporting documents to validate input VAT claims.

     3. Regularization of Outstanding Liabilities

        • Settle any outstanding VAT arrears.

        • Enter into payment plans if unable to clear the arrears at once.

     4. Engagement with KRA

        • Apply for review and removal from the table through the KRA iTax system.

        • Provide sufficient evidence of compliance during KRA reviews.

     Once KRA is satisfied that you have aligned with all requirements, your business can be delisted from the VAT Special Table.

     Applicable Tax Laws

     The VAT Special Table and ETIMS requirements are anchored in Kenyan tax legislation, including:

     • Value Added Tax Act, 2013 – Provides the legal framework for VAT administration, including registration, filing, and invoicing.

     • Tax Procedures Act, 2015 – Governs compliance, enforcement, and penalties.

     • Finance Act, 2022 & Finance Act, 2023 – Introduced mandatory ETIMS usage and compliance obligations.

     • KRA Public Notices & Guidelines – Provide practical steps for onboarding, invoice transmission, and taxpayer obligations.

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     Final Thoughts

     The VAT Special Table is not meant to punish businesses but to enforce transparency and curb fraudulent VAT practices. For taxpayers, the best way to avoid being onboarded—or to be removed—is simple: embrace ETIMS, stay compliant, and maintain accurate tax records.

     By aligning your business operations with the applicable tax laws, you not only stay off the radar but also build credibility and sustainability in the long run.