Compliance

Record-Keeping for China Imports: What KRA Expects

Import records matter long after the goods have sold. Here is what a Kenyan importer should keep, why, and for how long.

SSilkBridge··3 min read

The documents around an import have a second life. Long after the container has been cleared and the stock sold, those papers are what substantiate your cost of sales, support your input VAT position and answer questions from the Kenya Revenue Authority. Importers who treat paperwork as a clearing formality tend to discover this at the least convenient moment.

Key takeaways
  • Records generally must be kept for 5 years under the Tax Procedures Act 2015.
  • Customs entries, invoices and payment evidence should tie to one another.
  • Payment records substantiate the cost you are claiming, not merely that you paid.
  • Freight, duty and clearing costs belong in landed cost, so keep those documents too.
  • This is general information — take advice from your own tax adviser on your position.

What to keep

DocumentWhy it matters later
Proforma and commercial invoiceEstablishes what was bought and at what price
Customs entry and assessmentEvidences duty and VAT paid at import
Bill of lading or air waybillProves shipment and terms of carriage
Payment confirmationTies the money paid to the goods received
Freight and clearing invoicesSupports the landed cost you booked
Supplier correspondenceExplains variations, credits and disputes

The set matters more than any single item. A customs entry without the matching payment evidence, or an invoice with no proof it was settled, leaves a gap exactly where a question is most likely to land.

How long, and in what form

Under section 23 of the Tax Procedures Act 2015, documents required under a tax law must generally be kept for 5 years. Where a matter is under audit, objection or appeal, retain everything relating to it until that is concluded, regardless of age.

Confirm your own positionRetention periods and their exceptions can change, and specific circumstances vary. Treat this as orientation and confirm with your tax adviser rather than relying on it as advice.

Digital copies are the practical choice for most importers, provided they are legible, complete and retrievable. A folder of unnamed phone photographs is not a record system — the test is whether you could produce the full set for a specific consignment on request, years later.

Organising so the set stays together

  1. 1Give every consignment a reference and use it consistently across all documents.
  2. 2Keep one folder per consignment rather than one folder per document type.
  3. 3File the payment confirmation with the invoice it settles, not separately.
  4. 4Record the exchange rate used, so the shilling cost can be reconstructed.
  5. 5Store copies somewhere that survives a lost laptop or a closed email account.

Recording the rate deserves particular attention. Your accounts are in shillings and your invoice is not, so the conversion is part of the record. Without it, reconstructing landed cost years later becomes guesswork — and guesswork is difficult to defend.

Close each consignment file onceWhen a consignment clears, spend 10 minutes completing its folder while the detail is fresh. Reconstructing it 2 years later, from memory and a mailbox, takes far longer and produces a worse record.

One habit is worth more than any filing system: write a single short note per consignment recording anything unusual — a price change, a partial shipment, a credit, a delay and its cause. Those explanations are exactly what a question years later turns on, and they are the first thing memory loses.

Frequently asked questions

Are digital copies acceptable?

Digital records are widely used, provided they are complete, legible and can be produced when required. Confirm the specific requirements for your circumstances with your tax adviser.

Do I need records for goods I have already sold?

Yes. The retention obligation runs from the relevant tax period, not from when the stock left your warehouse. Sold goods are precisely what your cost of sales figure relies on.

What if a supplier will not issue a proper invoice?

That is a problem worth resolving before you pay rather than after. An import you cannot substantiate creates difficulty on both the customs and the tax side, and the time to insist on documentation is while you still hold the money.

S
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