Charity Muindi

Charity began her legal career as a Legal intern at Muma & Kanjama Advocates in 2022. She later joined Cliffe Dekker Hofmeyr as a Trainee Advocate in January 2024 and was appointed as an Associate in the Tax & Exchange Control in July 2025. Charity holds a Post-Graduate Diploma from the Kenya School of Law and a Bachelor of Laws degree from the University of Nairobi.

Tax and legal structuring

• Part of a team that advised a leading educational services provider in Kenya on the financial and tax structuring of a proposed divestment transaction involving the sale of shares to a group of investors, including the possible sale of shares by existing shareholders and the hiving off of a subsidiary. The engagement involved reviewing the historical performance and financial projections of the subsidiary, assessing its debt-carrying capacity, and evaluating options for right-sizing its balance sheet. Additionally, the engagement included providing a tax restructuring advisory, including guidance on the tax implications of share acquisitions, transfer of family-owned property, the formation of a holding company, and the transfer of loan obligations, along with recommendations on the most tax-efficient structuring for the divestment.
• Part of a team that advised a real estate development and agricultural investment company on the best structuring.
• Part of a team that provides monthly tax training to the East African branch of a high-end global corporation. We train on the Social Health Insurance Fund, the Kenya-French Double Tax Agreement, recent tax bills / laws, transfer pricing, tax exemption for Japanese companies among others.
• Part of a team that advised a global IT services and technology solution provider, on the implication of making advance payments to the client's related party for the purchase of software licenses. The advice was coming at a time when Kenya had indicated that it would change the tax regime for software which would have negatively impacted the client.
• Part of a team that advised a project proponent of a REDD+ carbon project in Kenya on the application of taxes under both the relevant regulations and Kenyan law, including timing and assessment of taxes for sales executed by a separate marketing agent outside Kenya. The scope included guidance on income tax, withholding tax (WHT) implications, VAT and indirect tax considerations, and potential tax incentives in Kenya.
• Part of a team that advised a Kenyan subsidiary of a US carbon project developer on managing tax risks associated with its business model, including reviewing financial statements and proposed intercompany transactions, identifying and advising on tax and transfer pricing risks arising from costs incurred both locally and by its parent company, advising on mitigation strategies, and drafting a company transfer pricing policy and an intercompany service agreement to support regulatory compliance and manage potential Kenya Revenue Authority queries.
• Part of a team that advised a company on tax considerations on trading in carbon credits in Kenya which was on transfer pricing implications of the client's intercompany transactions.
• Part of a team that advised a high-end healthcare facility on a potential tax impact of its proposed corporate restructure and expansion programme for the rest of East Africa. We further advised on measures it could put in place to restructure its operations in a tax -efficient manner while minimising tax impact on the acquisition of a stake by an equity or debt investor.
• Part of a team that advised a leading security and investigative company on the tax implications on transfer of contracts from a Kenyan entity to Dubai entities.

Tax dispute resolution

• Part of a team that is supporting a Luxembourg-based investment fund undergoing tax audit by the Kenya Revenue Authority. We assisted with checking on the tax exposure prior to audit, preparing documentation for audit purposes, and holding the client's hands during the audit meetings.
• Part of a team assisting a European company involved in market research with operations across 34 countries on the African continent in objecting to KRA tax assessment.

Mergers and Acquisitions 

• Part of a team that conducted a buyer tax due diligence and advised on the acquisition of a fast-food franchise in Kenya.

Insolvency 

• Part of a team that is assisting Australian call center company with the members' voluntary liquidation of its Kenyan subsidiary that has ninety-five employees.
• Part of a team that is assisting a leading automotive company with member's voluntary liquidation of its subsidiary in Kenya.

Corporate & Commercial

• Part of a team that represented two private investors in their acquisition of 51% of the issued share capital in a Kenyan coffee roasting and resale company. This involved the review of the targets corporate and regulatory compliance and the drafting and negotiation of the required transaction documents. Advised a company in the hospitality industry in securing an equity investment of USD 1,200,000 from various investors. This included assistance with increasing the shares in the company, drafting and negotiating a share subscription agreement for the purchase of new shares in the company, and a shareholders' agreement to govern the relationship between the investors and existing shareholders. She also amended the company's articles of association to align with the provisions of the shareholders' agreement.