supply of imported services means a supply of services that satisfies the following conditions—

1. the supply is made by a person who is not a registered person to a person who is a registered person;
2. the supply would have been a taxable supply if it had been made in Kenya; and
3. the registered person would not have been entitled to a credit for the full amount of input tax payable if the services had been acquired by the person in a taxable supply;