The agreement was signed on Tuesday, 30 September 2025, at the National Treasury offices in Nairobi.
Representatives from Kenya and Belgium have signed a tax treaty aimed at eliminating double taxation and preventing tax evasion for individuals and businesses operating between the two countries.
The agreement was signed on Tuesday, 30 September 2025, at the National Treasury offices in Nairobi. Treasury Cabinet Secretary John Mbadi and Belgium’s Ambassador to Kenya, Peter Maddens, officiated the signing ceremony.
The treaty is primarily based on the OECD Model (2017) while incorporating some aspects from the UN Model (2021).
The treaty applies to Belgian individual income tax, corporate income tax, income tax on legal entities, income tax on non-residents, and withholding tax on immovable property.
The Belgium-Kenya Income Tax Treaty (2025) sets maximum withholding tax rates of 10% on dividends (8% for qualifying companies or pension funds), 8% on branch profits, 12% on interest (0% in certain government or public entity cases), 10% on royalties, and 10% on technical service fees.
Belgium applies both credit and exemption methods with progression, while Kenya uses the credit method for double taxation relief.
Mbadi said the framework seeks to remove barriers to cross-border trade and investment by eliminating instances of double taxation and establishing greater predictability in tax matters. He emphasised that the agreement also provides mechanisms to curb tax evasion and promote transparency and fairness within the tax systems of both nations.
“This signing builds on the momentum of the 2024 Kenya-Belgium Political Consultations in Brussels, during which both countries reaffirmed their commitment to broaden cooperation in trade and investment,” said Mbadi.
He added that the new treaty is expected to strengthen bilateral relations and create a more conducive environment for businesses and investors, thereby deepening economic and diplomatic ties between Kenya and Belgium.
The treaty will enter into force upon the exchange of ratification instruments and will be effective from 1 January of the year following its entry into force.
