Brian Kanyi

Full Profile

Brian is Head of Tax at Clyde & Co’s Nairobi office, where he leads the tax practice. He advises multinational and regional corporations, financial institutions, investors, and nonprofit organisations on international tax structuring, tax advisory, mergers and acquisitions (M&A) tax, transfer pricing, tax policy, and tax disputes.

Brian has advised clients operating in the energy and natural resources, financial services, healthcare, infrastructure, insurance and reinsurance, retail and consumer, telecommunications, and technology sectors. His experience covers high-value tax disputes, cross-border transactions, corporate reorganisations, market entry, investment projects, and engagement on tax policy and legislative reform.

Brian is an Advocate of the High Court of Kenya. He graduated with a Master of Laws degree (LLM) in Corporate and International Tax Law and a Bachelor of Laws degree (LLB) from Strathmore University. He also holds a Postgraduate Diploma in Law from the Kenya School of Law.

Prior to joining Clyde & Co, Brian worked in the tax consulting practice at PwC in Nairobi and in the tax and legal practice at Dentons Hamilton Harrison & Mathews in Nairobi.

Brian is fluent in English and Kiswahili.

Experience

• Advising a global technology corporation in a USD 52.3 million corporate income tax dispute concerning transfer pricing, permanent establishment, and statutory limitation issues. *
• Advising a multinational telecommunications group in a USD 564 million dispute concerning corporate income tax, VAT, excise duty, and transfer pricing assessments. *
• Acting for a regional commercial bank in a USD 1.8 million VAT appeal concerning the tax treatment of card transaction fees. *
• Acting for a regional financial technology and remittance provider in a USD 2.83 million excise duty appeal concerning the tax treatment of foreign exchange margins. *
• Advising a multinational mining operator in a USD 14.3 million dispute concerning transfer pricing and interest deduction limitations. *
• Advising an international digital services business on a capital gains tax dispute concerning the valuation of a share transfer. *
• Advising a multinational telecommunications group on the tax aspects of a corporate acquisition, covering capital gains tax, and regulatory requirements. *
• Advising a multinational ecommerce group on a cross-border reorganisation, covering indirect transfer tax, stamp duty, debt restructuring, transfer pricing and the preservation of tax losses. *
• Advising a multinational group on market-entry and investment structures, covering acquisition funding, holding companies, treaty access, withholding tax, and permanent establishment risk. *
• Advising industry participants on tax proposals affecting virtual assets and supporting engagement with policymakers on legislative reform. *
• Advising a regional nonprofit on renewing its income tax exemption under Kenya’s charitable organisation exemption rules. *

*Experience gained prior to joining Clyde & Co