On 9 November 2026, the Kenya Revenue Authority (KRA) issued a public notice requiring multinational groups within the scope of the Minimum Top-Up Tax (MTT) under section 12G of the Income Tax Act to comply with the newly published Income Tax (Minimum Top-Up Tax) Regulations, 2026.
If your group, or any member of it, operates in Kenya, we recommend confirming your position now. The first deadline falls in less than three weeks.
KEY DEADLINE
30 November 2026Notification of in-scope status to the Commissioner, via KRA’s dedicated channel.
WHAT KRA REQUIRES
Three obligations for covered groups
Notify the Commissioner of in-scope status, stating the group’s name, the jurisdiction of the Ultimate Parent Entity, and each Kenyan constituent entity with its KRA PIN. By 30 November 2026.
File MTT returns and pay any top-up tax due on Kenyan profits taxed below the 15% minimum effective rate. As prescribed in the Regulations.
Adhere to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information, including GloBE Information Return arrangements. Ongoing
ARE YOU IN SCOPE?
Who the rules capture
Section 12G, introduced by the Tax Laws (Amendment) Act, 2024, implements the OECD Pillar Two framework in Kenya. Broadly, it applies to Kenyan constituent entities of multinational groups with consolidated annual revenue of at least EUR 750 million in at least two of the four preceding fiscal years. This includes Kenyan subsidiaries, branches and permanent establishments of foreign groups, as well as Kenyan-headquartered groups with operations abroad.
RECOMMENDED NEXT STEPS
What to do before 30 November
■Confirm group revenue against the EUR 750 million threshold for the relevant look-back years.
■Map every Kenyan constituent entity and confirm its KRA PIN.
■Coordinate with group tax on the Ultimate Parent Entity details and the group’s GloBE filing approach.
■Submit the notification to the Commissioner and keep proof of submission.
■Model the Kenyan effective tax rate, particularly where incentives, exemptions or SEZ/EPZ regimes reduce tax below 15%.