VAT returns for clients with very many sales

How a Kenyan client with very many sales invoices declares them in its iTax VAT return: the sheet B row limit, the lump-sum field and CSV import.

By Achekam · 11 October 2026 · 4 min read · For Accountants & audit firms in Kenya

A wholesaler with thousands of trade customers, a distributor invoicing every outlet on a route, a utility billing every account each month: some Kenyan clients produce more sales invoices in a month than a VAT return form was ever meant to list. The preparer's question is practical. Must every invoice go in line by line, and if not, what happens to the rest?

KRA has answered it. There is a ceiling on the number of rows in the sales sheet, a field for everything beyond it, and a way to load large data without typing. There are also rules about pre-populated sales that apply with special force to a high-volume client, because small timing differences multiply across many invoices.

The row limit in sheet B and the lump-sum field

KRA says sales to VAT-registered customers can be declared line by line up to a maximum of 75,000 rows in sheet B, with the taxable value of any further invoices added to the lump-sum sales field. KRA's FAQs on the VAT auto-populated return set out how sheet B and the pre-filled figures work.

So a client below the limit lists every sale to a registered customer individually. A client above it lists up to the limit and puts the taxable value of the remainder in the lump-sum field. Nothing is left out; the excess is simply declared as a total rather than invoice by invoice.

Decide in advance which invoices go line by line. A sensible rule is to list the largest invoices individually and put the long tail of small ones in the lump sum, so the itemised part of the return covers most of the value. Whatever the rule, write it down and apply it the same way each month.

Importing from CSV instead of typing

KRA says iTax returns are downloaded as Excel forms, completed offline with macros enabled, and uploaded as a generated zipped file, and that large data sets can be imported into the return from CSV.

For a high-volume client, CSV import is the only realistic route. Prepare the CSV from the client's sales listing in the column order the return expects, import it into the downloaded form, and generate the upload file from there. Keep a copy of the CSV exactly as imported; it is the line-level record of what the return declared.

Pre-populated sales and invoice dates

KRA says the auto-populated VAT return is pre-filled with information from iTax, TIMS, eTIMS and the customs systems, and that VAT-registered taxpayers must verify and confirm its accuracy. Two further rules shape the work:

• a taxpayer cannot reduce the pre-populated sales below what was transmitted through TIMS/eTIMS, but can adjust sales upwards, for example for sales made outside TIMS/eTIMS;
• sales are pre-populated by invoice date, not transmission date, so all sales for the period must be declared whether or not they were transmitted by the filing date.

For a client with many invoices, the invoice-date rule matters most. Invoices raised on the last day of the month and transmitted the next morning still belong to the month they were raised. A sales listing cut by transmission date will not agree with KRA's figures, and the difference cannot be fixed by reducing the pre-filled sales. See the auto-populated VAT return for more.

Working from the client's schedules in Achekam

Achekam computes a client's Kenyan VAT return from the sales and purchase schedules the firm imports, because the client's own books are not linked to it. For a high-volume client, the schedule is therefore both the input to Achekam's computation and the source of the CSV prepared for iTax. Use the same export for both, so that the figure computed in Achekam and the figure uploaded to iTax come from one file.

The client's trial balance can be read into Achekam as well: staff can upload it as an Excel workbook, a CSV file or a PDF that has a text layer. That gives the reviewer the ledger's sales figure to set beside the schedule's total, which is the most useful single check on a return with too many lines to inspect.

The method for building returns from client schedules is set out in preparing client VAT from schedules.

Totals the reviewer should tie out

With tens of thousands of lines, the reviewer cannot check invoices; they check totals. Before upload:

1. Line-by-line sales in sheet B plus the lump-sum field equals total sales to registered customers in the schedule.
2. Total declared sales is not below the pre-populated eTIMS figure.
3. Any upward adjustment is explained, for example sales made outside eTIMS.
4. The schedule's sales agree with the trial balance for the period, with reconciling items listed.
5. The schedule was cut by invoice date, not transmission date.
6. Credit notes are shown as negative lines quoting their invoices, as described in entering credit notes in a client's iTax VAT return.

Keeping line-level support on file

The lump-sum field holds a total, but the client still has the invoices behind it, and KRA may ask about any of them. Keep the full listing that makes up the lump sum, in the same form each month, with the CSV that was imported and the generated upload file. If a question comes a year later, the firm can show exactly which invoices sat inside the total and why.

General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.