Sterling & Wilson settles Kenya tax demand of ₹26.50 crore for ₹2.66 crore
- Settled KRA demand of ~₹26.50 crore for FY20-23 assessments
- Final payment capped at ~₹2.66 crore principal only
- Interest and penalties waived upon payment by December 25, 2026
- Reduction driven by lower profit attribution to Kenya branch

*this image is generated using AI for illustrative purposes only.
Sterling & Wilson Renewable Energy Limited has entered into a full and final settlement agreement with the Kenya Revenue Authority (KRA), reducing a tax demand of ~₹26.50 crore to ~₹2.66 crore.
The settlement pertains to assessments for calendar years 2020 to 2023. The original demand, issued via an order dated December 12, 2025, included interest and penalties. Under the new agreement, the company will pay only the principal amount, effectively writing off the associated interest and penalties.
Settlement Terms and Financial Impact
The company disclosed this development under Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The settlement absolves Sterling & Wilson from paying interest and penalties, provided the principal demand is paid by December 25, 2026, and other applicable legal compliances are met.
The reduction in liability stems from a lower attribution of profits to the company's Kenya branch during the assessment period. The expected financial implication on the listed entity is limited to the principal payment of ~₹2.66 crore.
Key Settlement Details
| Particulars | Details |
|---|---|
| Authority | Kenya Revenue Authority (KRA) |
| Period Covered | January 1, 2020 to December 31, 2023 |
| Original Demand | ~₹26.50 crore (including interest and penalties) |
| Settled Amount | ~₹2.66 crore (principal only) |
| Payment Deadline | December 25, 2026 |
| Penalties Imposed | Nil |
What the Numbers Show
The settlement represents a significant reduction in contingent liabilities, with the final payable amount constituting approximately 10% of the original demand. This outcome highlights the impact of profit attribution methodologies on cross-border tax exposures, as the primary driver for the reduced liability was the lower attribution of profits to the Kenya branch rather than a dispute over the underlying transactions themselves.
Historical Stock Returns for Sterling & Wilson Renewable Energy
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| -4.85% | -9.14% | -13.42% | -21.41% | -32.69% | -64.39% |
How might this precedent influence Sterling & Wilson's approach to profit attribution in other high-tax jurisdictions?
Will the successful settlement improve Sterling & Wilson's credit rating or borrowing costs for future international projects?
Could this case prompt the Kenya Revenue Authority to revise its transfer pricing guidelines for foreign contractors?


































