KRA gives multinationals in Kenya until 30 November to declare minimum tax status

Multinational groups covered by Kenya's minimum top-up tax must notify the Kenya Revenue Authority (KRA) by 30 November 2026 that they are in scope, the tax authority said in a public notice dated 9 November 2026.

The notice is signed by the Commissioner for Large and Medium Taxpayers and titled "Compliance with Section 12G of the Income Tax Act (Cap. 470) and the Income Tax (Minimum Top-Up Tax) Regulations, 2026". It is addressed to "covered persons", the taxpayers that fall within the scope of the tax.

The notification must give the name of the group, the country of its ultimate parent entity, and a list of its Kenyan constituent entities with their KRA PINs. It goes by email to [email protected], which is also the address for clarification and guidance. The notice gives KRA's address as Times Tower Building, Haile Selassie Avenue, Nairobi, P.O. Box 48240-00100.

Notification is the first of three requirements in the notice. Covered persons must also file a return declaring the minimum top-up tax (MTT) and pay any tax due, and they must adhere to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.

The tax was introduced as section 12G of the Income Tax Act by the Tax Laws (Amendment) Act, 2024. The Income Tax (Minimum Top-Up Tax) Regulations, 2026 were published as Legal Notice No. 189 on 18 September 2026.

The Kenyan news site Kenyans.co.ke and the newspaper The Standard both reported on 9 November that the tax requires large multinationals to pay at least 15% tax on their profits. Both said a group is covered if its combined annual revenue is at least KSh 110 billion in at least two of the previous four financial years. That is about US$846 million, or 5.7 billion yuan, at KSh 129.96 to the dollar (the Central Bank of Kenya rate on 5 November) and 6.7168 yuan to the dollar (China's central parity rate on 6 November).

Kenyans.co.ke added that a Kenyan subsidiary could be affected even if its own revenue is below KSh 110 billion, provided the wider group meets the threshold. It said companies whose effective tax rate falls below 15% may owe the difference, subject to adjustments under the regulations.

Both outlets said companies have 21 days from the notice to notify KRA.