Kenya Revenue Authority (KRA) issued a notice on Monday, November 9, granting multinational firms operating in Kenya a 21-day period to indicate whether they are subject to the newly introduced minimum top-up tax of 15 per cent on profits.
The directive instructs companies that meet the Minimum Top-Up Tax (MTT) criteria to inform the Commissioner of their status by November 30, 2026 and to provide details of their group, including the ultimate parent’s country and a list of Kenyan entities with their KRA Personal Identification Numbers.
KRA stated that the notification must contain the group name, the ultimate parent’s country and the roster of Kenyan entities with their PINs, saying: "Notify the Commissioner of being in scope, including the group name, Country of the Ultimate Parent Entity, and a listing of Constituent entities in Kenya with their PINs."
The MTT applies to multinational groups whose combined annual revenue reaches at least KSh110 billion in any two of the previous four financial years, and those identified as in scope must file MTT returns and settle any additional tax liability.
The authority added that all covered taxpayers should submit a declaration return and pay any minimum top-up tax due, noting: "We therefore wish to inform all taxpayers covered in the scope of the MTT to file a return for declaration of MTT and pay any minimum top-up tax due."
A further requirement is compliance with the Multilateral Competent Authority Agreement on the Exchange of GloBE Information, which establishes a framework for tax authorities to share data on multinational enterprises.
The 15 per cent minimum tax was introduced through the Tax Laws (Amendment) Act, 2024, which added Section 12G to the Income Tax Act, and KRA released implementing regulations in 2026 to guide the regime’s application.
