What Is the VAT Special Table?
The VAT Special Table (also called the Special Suppliers Table) is a KRA-maintained database of suppliers flagged for VAT non-compliance. It is separate from the general taxpayer register — it specifically tracks suppliers whose input VAT claims KRA does not trust.
When you file your monthly VAT return on iTax and enter purchases from a supplier on the Special Table, the system automatically rejects your input VAT claim for that particular supplier. You will see a warning or error message referencing the Special Table. The rejection is automatic — no human review involved.
The Special Table was created to combat VAT carousel fraud and invoice mills — schemes where fake invoices are used to claim fraudulent input VAT refunds from KRA. However, it also catches legitimate businesses that have fallen behind on compliance without realising the consequences.
KRA website finding: The KRA VAT FAQ page mentions the Special Table, warning that filing consecutive nil returns can land you on it and block your customers from claiming input VAT on your invoices. This confirms that the nil return flagging risk is real and documented by KRA itself.
How Suppliers Get on the Special Table
KRA does not publish exact criteria, but based on observed cases and KRA guidance, suppliers are typically flagged for one or more of the following:
Consecutive nil returns (6+ months)
High — one of the most common triggers for legitimate small businessesFiling nil returns for 6 to 12 months in a row triggers a compliance review. KRA questions whether a business can operate for that long with zero activity.
eTIMS non-compliance
High — escalating enforcement from January 2026Not registered for eTIMS or issuing invoices outside the eTIMS system. Since eTIMS is mandatory for all businesses, non-compliance is a red flag.
Discrepancy between eTIMS data and returns
Medium — caught by KRA's automated cross-checkingIf your eTIMS invoice data shows sales but your VAT return declares lower amounts, KRA flags the mismatch automatically.
Late filing pattern
Medium — depends on frequency and latenessFiling consistently late (even by a few days) can build a compliance risk profile that lands you on the Special Table.
Audit finding of under-declaration
Very High — usually involves penalties tooIf a KRA desk audit or field audit finds you under-declared sales, you will likely be added to the Special Table as part of the remedial action.
Suspicious invoice patterns
Medium — KRA's analytics system flags anomaliesIssuing invoices that look irregular (round-number amounts, rapid escalation in invoice volume, invoices to related parties) can trigger a review.
Consecutive Nil Returns: A Hidden Risk
This is the most overlooked trap in Kenya VAT compliance. Filing nil returns is the right thing to do when you have no activity — but filing them month after month without a break can flag you in KRA's system.
Here is the logic from KRA's perspective: if a business has zero sales, zero purchases, zero expenses for six straight months, is it really operating? KRA's compliance system flags such taxpayers for review. If your business genuinely has a seasonal or pre-launch period with no activity, you may be fine — but you need to be prepared to explain.
How to avoid nil return flagging
- If you have even small activity (KES 1,000 in sales or KES 500 in purchases), file it — do not file a nil return when you have real transactions.
- Keep records of why you filed nil returns — pre-launch phase, seasonal business, restructuring, etc.
- If you registered for VAT but have not launched yet, consider whether voluntary registration was the right move. A business with no activity for 12+ months should not be VAT-registered.
- Consider de-registering from VAT if you consistently have nil activity for 12 months. KRA allows voluntary de-registration if you meet the criteria.
- If you are flagged, respond promptly — ignoring KRA's compliance inquiry can escalate to the Special Table.
Confirmed by KRA's own guidance
The KRA website's VAT FAQ page explicitly states that filing consecutive nil returns can result in your business being added to the VAT Special Table, which blocks your customers from claiming input VAT on your invoices. This is not a rumour — it is official KRA policy.
See our nil returns and tax amnesty guide for detailed instructions on filing nil returns correctly.
What Happens When You Buy From a Flagged Supplier
If you purchase goods or services from a supplier on the VAT Special Table, here is exactly what happens:
- You receive an eTIMS invoice from the supplier (or a manual invoice if they are non-compliant).
- You enter the purchase and the input VAT amount on your monthly VAT return on iTax.
- iTax cross-checks the supplier's KRA PIN against the Special Table database.
- If the supplier is listed, iTax rejects the specific input VAT line item automatically.
- You receive an error message or warning on the return. The rest of your return processes normally, but that particular input claim is disallowed.
- If you have already claimed the input VAT before KRA updated the Special Table, you may face an additional assessment on audit.
The cascading effect
If you are a supplier and your customers cannot claim input VAT on your invoices, they will stop buying from you. A B2B business that cannot pass the VAT deduction to its customers is at a severe competitive disadvantage. This creates a powerful market incentive to stay off the Special Table — your customers will demand it.
How to Check Your Status
There is no public database or search tool where you can check if a supplier is on the VAT Special Table. Here is how you find out:
Check your iTax return
When you file your monthly VAT return and enter a purchase from a flagged supplier, iTax will display a warning or error message. This is the most reliable way to discover a supplier is on the list.
Customer complaints
If your own customers start telling you that their input VAT claims are being rejected, it is likely you have been added to the Special Table. This is often how businesses first find out.
KRA compliance letter
KRA may send a formal notification via iTax or physical mail if you have been flagged. Check your iTax messages regularly.
KRA audit or field visit
During a compliance audit or field visit, a KRA officer may inform you of your Special Table status and explain the steps to remedy it.
Proactive tip: If you are a VAT-registered business making significant purchases (over KES 100,000 per supplier per month), verify your suppliers' compliance status before committing. Ask for their KRA PIN and confirm they are issuing eTIMS invoices. A small upfront check can save you thousands in blocked input VAT claims.
How to Get Removed from the Special Table
Removal from the VAT Special Table is not automatic — you must demonstrate sustained compliance and actively request removal. Here is the process:
File all outstanding returns
If you have missed any VAT returns (including nil returns), file them immediately. KRA will not consider removal while you have outstanding filings.
Pay any outstanding penalties or taxes
Clear all outstanding balances. If you need a penalty waiver, apply for it through iTax under Penalty and Interest Waiver before requesting Special Table removal.
Demonstrate consistent compliance (3-6 months)
File your returns on time (before the 20th) for at least 3 consecutive months. KRA wants to see that your compliance was not a one-time event.
Contact KRA or visit your iTax dashboard
Access your iTax portal and send a message to KRA requesting a compliance review and removal from the Special Table. Include your KRA PIN, a brief explanation of the steps you have taken, and attach proof of compliance.
Attend a KRA compliance meeting (if required)
KRA may schedule a meeting with a compliance officer to discuss your case. Bring records of your returns, eTIMS invoices, and any correspondence. If you have a KRA-registered agent, they can represent you.
Receive confirmation of removal
If approved, KRA will update the Special Table and notify you via iTax. Your customers will once again be able to claim input VAT on your invoices.
We Can Help With Special Table Removal
Smart VAT Kenya handles VAT Special Table removal for KES 4,000 per application. We draft the compliance letter, compile your filing history, and manage communication with KRA on your behalf. Most cases are resolved within 2 to 4 weeks.
Get Special Table HelpProtecting Your Business: Due Diligence Checklist
Use this checklist to reduce your risk of being flagged or buying from a flagged supplier:
| Action | Why | |
|---|---|---|
| File every return before the 20th — including nil returns | Consistent on-time filing is your best defence against being flagged | |
| Onboard eTIMS and issue compliant invoices | eTIMS compliance is mandatory and reduces audit risk | |
| Verify your suppliers use eTIMS before making large purchases | Non-compliant suppliers may be on the Special Table, blocking your input VAT | |
| Avoid consecutive nil returns if you have any activity at all | Even small transactions should be declared to avoid triggering KRA's nil return flag | |
| Keep records of reasons for nil periods (pre-launch, seasonal, etc.) | If flagged, you need evidence to explain the inactivity | |
| Check your iTax messages regularly for KRA compliance notices | Early awareness of a flag gives you time to respond before it escalates | |
| Respond promptly to any KRA compliance inquiry | Ignoring KRA communication can result in automatic Special Table addition | |
| Use Buyer-Initiated Invoicing if a key supplier is not yet on eTIMS | BII lets you claim input VAT while giving the supplier time to onboard |
Frequently Asked Questions
- What is the KRA VAT Special Table?
- The VAT Special Table is a KRA-maintained list of suppliers flagged for non-compliance. If you purchase from a supplier on the Special Table, your input VAT claim on that purchase is automatically rejected by the iTax system — even if your return is otherwise correct and filed on time.
- Can filing nil returns put me on the Special Table?
- Yes. Filing consecutive nil returns over 6 to 12 months can trigger a KRA compliance review, which can result in you being added to the VAT Special Table. KRA reasons that a business filing consistent nil returns may be under-reporting sales. To avoid this, ensure your nil returns are legitimate — and if you do have activity, file a normal return.
- How do I check if a supplier is on the VAT Special Table?
- There is no public list. You can only find out when you file your VAT return on iTax and your input VAT claim is rejected with a warning referencing the Special Table. However, KRA compliance officers may inform you during an audit. The best defence is to verify your suppliers are eTIMS-compliant and actively filing returns.
- How do I get my business removed from the VAT Special Table?
- Removal from the Special Table requires filing all outstanding returns, paying any penalties, and demonstrating consistent compliance — usually 3 to 6 months of on-time, accurate returns. In serious cases, you may need to meet with a KRA compliance officer. Smart VAT Kenya can help draft a compliance letter and manage the removal process.
- What happens if I buy from a supplier on the Special Table?
- Your input VAT claim is automatically rejected. You cannot claim that input VAT on your return. If you have already claimed it and KRA audits your return, you will face an additional assessment plus penalties and interest. The Buyer-Initiated Invoicing (BII) mechanism can help: you can generate an eTIMS-compliant invoice on behalf of the supplier, which may allow your input claim to go through while pressuring the supplier to regularise their status.
- Is the VAT Special Table the same as a KRA blacklist?
- Not exactly. The Special Table is specifically a VAT compliance flag — it blocks input VAT claims from that supplier. A KRA blacklist is a broader designation that can affect your ability to clear goods at customs, get tax compliance certificates, or bid for government tenders. Being on the Special Table can escalate to a broader blacklist if non-compliance continues.
- How does eTIMS relate to the VAT Special Table?
- eTIMS and the Special Table are connected. Suppliers who fail to onboard eTIMS or who issue non-compliant invoices are prime candidates for the Special Table. Conversely, being eTIMS-compliant and filing regular returns is the best way to avoid being flagged. KRA's real-time invoice data from eTIMS is used to cross-check returns — discrepancies can trigger a Special Table review.