The Kenya Revenue Authority (KRA) has introduced new compliance requirements for businesses falling within the scope of the Minimum Top-Up Tax (MTT).
In a public notice issued on November 9, KRA directed covered taxpayers to disclose their multinational group structures.
The authority explained that the directive is part of the implementation of Kenya’s Minimum Top-Up Tax framework.
According to KRA, the affected taxpayers must also file the relevant MTT returns, pay any minimum top-up tax due and comply with international information exchange requirements under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.
“The Kenya Revenue Authority therefore wishes to inform all taxpayers who are in scope of the MTT to ensure full compliance with section 12G of the Income Tax Act and the Legal Notice No. 189 of 2026,” part of the statement read.
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KRA Sets November 30 Deadline for Taxpayer Notifications
Businesses covered by the MTT framework must submit a formal notification to the Commissioner by November 30, 2026, under the new directive.
The notification must include the name of the multinational group and the country of the Ultimate Parent Entity (UPE).
In addition, businesses must submit details of all constituent entities operating in Kenya, including their respective Personal Identification Numbers (PINs).
KRA has designated [email protected] as the official email address for submitting the required information.
What Is the Minimum Top-Up Tax?
The Minimum Top-Up Tax is part of the global minimum corporate taxation framework developed through the Organisation for Economic Co-operation and Development (OECD) and G20’s international tax reform initiative, commonly referred to as Pillar Two.
KRA notes that the international Pillar Two framework targets multinational enterprise groups with consolidated annual revenues of at least €750 million in at least two of the four fiscal years.
According to KRA, the framework seeks to ensure that large multinational enterprise groups pay a minimum effective tax rate on profits in the jurisdictions where they operate.
The minimum effective tax rate is generally set at 15% for multinational groups within its scope.
However, where the applicable effective tax rate in a jurisdiction falls below the minimum threshold, additional tax may arise,
The authority emphasises that additional taxes are subject to the applicable domestic legislation and calculation requirements.
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In Kenya, Section 12G of the Income Tax Act introduced the Minimum Top-Up Tax under the Tax Laws (Amendment) Act, 2024.
However, the implementation of the framework required additional regulations to provide the operational and administrative requirements for affected taxpayers.
Consequently, the Income Tax (Minimum Top-Up Tax) Regulations, 2026 were developed and published under Legal Notice No. 189 on September 18, 2026.
“The Minimum Top-Up Tax (MTT) was introduced under section 12G of the Income Tax Act (Cap. 470) via the Tax Laws (Amendment) Act, 2024. Subsequently, the Income Tax (Minimum Top Up Tax) Regulations, 2026 were developed and published via Legal Notice No. 189 on 18th September, 2026, KRA stated.
According to KRA, the regulations are intended to operationalise the MTT provisions and guide compliance with the new tax framework.
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