On 5 February 2019, Kenya's Court of Appeal reportedly issued a ruling on the meaning of the term 'paid' for tax purposes that has important implications for taxpayers. In an earlier decision of the Kenyan High Court regarding withholding tax on an accrued expense for which payment had not yet been made, it was determined that the term 'paid' means the actual delivery of money or other form of consideration. Based on the High Court decision, the prevailing practice has been that withholding t…