Confirming which tax obligations a client's PIN carries
How a firm confirms the tax obligations on a new Kenyan client's KRA PIN before taking on its compliance work, and what Achekam can check today.
By Achekam · · 5 min read · For Accountants & audit firms in Kenya
A new client arrives with a KRA PIN certificate and a promise that "everything is up to date". The firm agrees to handle its tax compliance from next month. Three months later, a penalty notice arrives for unfiled VAT returns the client never mentioned, because a VAT obligation was added to the PIN years ago when the business expected to grow.
The PIN is not the full picture. What matters for compliance is the set of obligations registered against it, because each obligation generates returns whether or not the client traded. A firm that confirms the obligations before accepting the work avoids inheriting problems it did not know about. This article explains why obligations matter, where to check them, and how Achekam fits into onboarding.
Every obligation means a return
KRA's guidance is consistent on this. Every person with a KRA PIN that has an income tax obligation must file an annual income tax return, and must file a nil return if they earned no income in the year. KRA also says that a person with a PIN who has not traded must still file nil returns for the periods without income.
The practical consequence is that a dormant obligation still produces filing deadlines. A client who registered for PAYE when it had staff, then let them go, still has a PAYE obligation on its PIN until it is dealt with. The same is true of VAT and other obligations. Nil returns are covered in more detail in nil returns in Kenya.
Why obligations get added
Obligations attach to a PIN when the law requires registration. KRA says a person who has accrued or expects to accrue a tax liability under the Income Tax Act or the VAT Act, or who expects to manufacture or import excisable goods or supply excisable services, must apply to the Commissioner to be registered.
PAYE is a common example. KRA says any person who pays emoluments to employees must register for the PAYE obligation, deduct tax from employees' pay, and remit and account for it to KRA. A client that took on its first employee should have added PAYE then. A client that employs people but has no PAYE obligation has a different problem.
So the review cuts both ways. The firm is looking for obligations the client no longer uses but still has to file for, and for obligations the client should have but does not.
Where to check
On iTax
The client can log in to iTax and show the firm which obligations are registered against the PIN. A screenshot or printout, dated, belongs on the onboarding file.
Through GavaConnect
KRA's GavaConnect developer portal offers government APIs, including a PIN checker that works by PIN or by ID, a Tax Compliance Certificate checker, a Tax Compliance Certificate application API, and a Fetch Taxpayer Obligations API. The GavaConnect developer portal lists these APIs, including the PIN checker, the tax compliance certificate checker and the taxpayer obligations lookup, for approved developers to use. More on what the portal offers is in GavaConnect APIs for Kenyan firms.
A review grid for the new client
| Obligation | Ask the client | Check against |
|---|---|---|
| Income tax | When was the last annual return filed? | Annual return history; nil returns for idle years |
| PAYE | Does the business have employees now? Did it in the past? | Monthly returns for every period the obligation was open |
| VAT | Is turnover near the registration threshold, or was VAT registered voluntarily? | Monthly VAT returns, including nil periods |
| Turnover tax or rental income tax | Is the client within either regime? | The relevant periodic returns |
| Excise | Does the client manufacture, import or supply excisable items? | Excise returns, if registered |
Any gap in filings found at this stage is a matter for the engagement letter: either the firm is engaged to clear it, or the letter records that it is outside scope.
What Achekam does at onboarding
The readiness checklist. Achekam's Onboarding page shows a readiness checklist for each new client, built from what the server holds, and offers "Mark active" only when every item is met. The items are registration and income tax numbers, an active service, a contact, an engagement and an account manager. A client without its KRA PIN recorded cannot be marked active, which prevents the most basic omission. The checklist does not list the obligations on the PIN; that review is the firm's.
The tax profile. Staff can open a Kenyan tax profile for the client and start returns that move through prepare, review and approve by different people. The client's sales and purchase lines are typed in, because the client's books are not linked to the profile. Payments are recorded with KRA's reference and confirmed by another person; Achekam does not pay the tax. Setting up a return for each obligation found in the review gives the firm a working list of what is due. The return workflow is described in the tax return workflow for Nigeria and Kenya.
The GavaConnect check, and its conditions
Achekam has a connector to GavaConnect, but it does not check KRA PINs and tax compliance certificates in production for a firm until three things are in place: the firm has entered its own GavaConnect approved-developer keys and addresses, the connection has passed a health check, and an Achekam platform administrator has authorised it for production. The connector's token and checker paths are held as configuration because the research could not confirm them. Nil return filing through GavaConnect is shown as coming soon and is not built.
Until that connection is live for a firm, the obligation review is done on iTax with the client.
Scope notes for the engagement letter
- List the obligations confirmed on the PIN at the start date, with the date of the check.
- Say which obligations the firm will file for, and which remain the client's.
- Record any backlog found and whether clearing it is part of the engagement.
- Ask the client to tell the firm before adding or removing an obligation.
Before the first return
Make the obligations check the first task on every new Kenyan tax client, before any return is prepared. A dated list of obligations, agreed with the client, is the foundation the rest of the engagement stands on.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
