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Naomi Musau

Naomi Musau

Senior Associate, IKM Advocates
[email protected] | vCard
Nairobi
  • Overview
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Naomi is a Senior Associate in the Tax Practice Group at the firm. She advises local and multinational clients on a wide range of tax and regulatory matters including international tax, tax structuring, employment taxes, and customs administration. Her work covers cross-border taxation, transfer pricing, permanent establishment risks, and general tax compliance, as well as advising and engaging with the Kenya Revenue Authority (KRA) on various tax and customs matters.

Naomi also has significant experience in tax and customs dispute resolution, representing clients before the Tax Appeals Tribunal (TAT), the High Court, and through alternative dispute resolution (ADR) mechanisms. She advises clients across multiple sectors, including banking and financial services, shipping and logistics, telecommunications, manufacturing, healthcare, charitable organizations, and real estate.

Experience has included :

  • As part of the team that represented ABSA Bank Kenya PLC at the TAT and at the High Court in a dispute on excise duty and Value Added Tax (“VAT”) on fees earned by banks in the industry. This was a leading case as it was the test case for the banking industry on VAT and excise duty on the Merchant Service Commission (“MSC”). 
  • As part of the team that represented Maersk Kenya Limited in a tax dispute at the TAT and in settling the dispute through the ADR framework.
  • As part of the team that represented a beer manufacturer at the TAT and the High Court in a dispute involving excise duty inflation adjustment and excise duty remission refund claims..
  • As part of the team that represented a cigarette manufacturer at the TAT and the High Court in a customs dispute with KRA and a nicotine products manufacturer at the TAT in a dispute with KRA in relation to customs classification of products.
  • Advising a multinational manufacturer on the legal and tax considerations in relation to special economic zones in Kenya including the legal framework covering originating criteria for SEZs, the tax exemptions applicable to SEZ entities, SEZ licensing and the tax, legal and licensing considerations of setting up an entity in the SEZ.
  • Advising a multinational bank on the tax and legal implications of establishing a shared service centre for offering services to related banks across the world.
  • Preparing legal opinions advising local and international clients on the tax implications of proposed investments and transactions including advising on permanent establishment risks, transfer pricing considerations and the applicable tax provisions in Kenya and advising clients on Double Tax Agreements applicable for cross-border transactions including the methods provided under bilateral agreements for elimination of double taxation.
  • Advising clients in their engagements with the KRA. These include assisting clients with tax audits and tax disputes with the KRA, carrying out tax compliance checks, assisting clients in preparation, lodging and follow up of applications for tax exemption status in Kenya, assisting clients with applications for waiver of penalties and interests accruing from their outstanding tax liabilities, and advising clients on customs administration and compliance including representing them in customs-related disputes before the Tax Appeals Tribunal (TAT) and Courts and in alternative dispute resolution (ADR).

Professional Qualifications

  • Advocate admitted to the High Court of Kenya (2021)

Education

  • Kenya School of Law, Postgraduate Diploma in Law (2021)
  • University of Nairobi School of Law, LL.B (2018)

Prior Experience

  • May 2025 to date, Senior Associate, DLA Piper Africa, Kenya (IKM Advocates)
  • May 2021 to May 2025, Associate, DLA Piper Africa, Kenya (IKM Advocates)
  • January 2020 – April 2021, Trainee Advocate,  DLA Piper Africa, Kenya (IKM Advocates)

Memberships

  • Member of the Law Society of Kenya (LSK)