What Has Changed?
The Finance Act, 2026 retained amendments to Section 10 of the Tax Procedures Act, providing a clearer process for taxpayers who had previously been deregistered but later qualify for tax registration.
1. Who Can Apply for Reinstatement?
If you previously deregistered your tax registration and later qualify for registration under Section 8 of the TPA, you are required to apply to the Commissioner for reinstatement.
This means you do not simply start operating under your old PIN without following the reinstatement process.
2. What Happens After Application?
Where the Commissioner is satisfied that you are liable for tax under a tax law:
- The Commissioner shall register you.
- You shall be issued the same PIN that was issued to you before deregistration.
This preserves continuity in your taxpayer records.
3. New 90-Day Written Notification
The Finance Act, 2026 introduces an important procedural enhancement:
The Commissioner must notify the applicant in writing of the decision on reinstatement within 90 days of receiving the application.
This provides a clear timeline for communication of the reinstatement decision.
Why Does This Matter?
For taxpayers who previously deregistered but later become liable for tax:
- There is a defined process for reinstatement.
- The same PIN can be issued, preserving historical taxpayer records.
- The 90-day written notification requirement provides greater certainty on when to expect a decision.
Simple Example
Emily previously deregistered her KRA PIN because she was no longer carrying on a taxable business.
Later, she starts a new business and qualifies for tax registration under Section 8.
She applies to the Commissioner for reinstatement.
If the Commissioner is satisfied that she is liable for tax, she will be registered and issued her previous PIN.
The Commissioner must notify her in writing of the reinstatement decision within 90 days of receiving her application.
Key Takeaway
Previously deregistered does not mean permanently excluded from tax registration.
Where you later qualify for registration, Section 10 provides a reinstatement process, including use of your previous PIN and a 90-day written notification timeline.
Effective date: 1 July 2026, unless otherwise specified in the Act.
Source: Finance Act, 2026 — Section 10, Tax Procedures Act, Cap. 469B. Page 20 of the PwC Tax Alert.
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