The Kenya Revenue Authority (KRA) has introduced new compliance requirements for multinational groups under the Minimum Top-Up Tax (MTT) framework. Affected businesses must submit formal corporate notifications by November 30, 2026. The KRA has directed all covered taxpayers to disclose their multinational group structures, file relevant MTT returns, and settle any minimum top-up tax liabilities due. This move aligns Kenya's corporate tax framework with global standards.
The KRA has set a strict deadline for taxpayer notifications, requiring businesses to submit a formal notification to the Commissioner by November 30, 2026. The notification must include the official name of the multinational group, the home country of the Ultimate Parent Entity (UPE), and detailed operational information of all constituent entities operating within Kenya, complete with their respective Personal Identification Numbers (PINs).
To streamline the submission process, the KRA has designated [email protected] as the official email channel for businesses to submit the required group structures and disclosures. Tax authorities have urged affected corporations to act promptly to avoid administrative penalties or compliance bottlenecks ahead of the approaching deadline.
The Minimum Top-Up Tax framework is part of the landmark international tax reform initiative developed through the Organisation for Economic Co-operation and Development (OECD) and G20, widely known as Pillar Two. The framework targets large multinational enterprise groups with consolidated annual revenues of at least €750 million in at least two of the preceding four fiscal years.
The primary objective of the Pillar Two framework is to ensure that large corporate entities pay a minimum effective tax rate on their profits in every jurisdiction where they conduct operations. The global minimum effective tax rate is standardized at 15% for multinational groups falling within its scope. If the applicable effective tax rate within a specific jurisdiction drops below this minimum threshold, an additional top-up tax arises.
In Kenya, the Minimum Top-Up Tax was initially established under Section 12G of the Income Tax Act (Cap. 470) via the Tax Laws (Amendment) Act, 2024. The operationalization of the framework required detailed administrative and regulatory mechanisms, which were published under Legal Notice No. 189 on September 18, 2026.
All persons covered by MTT are required to notify KRA that they are in scope by November 30, 2026, include the group name, the country of the Ultimate Parent Entity, and details of constituent entities in Kenya, including their PINs. They must also file the MTT return and pay any Minimum Top-Up Tax due, and comply with the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.
Key points
- The Kenya Revenue Authority has set a deadline of November 30, 2026, for multinational groups to comply with the Minimum Top-Up Tax framework.
- The Minimum Top-Up Tax framework aims to ensure that large corporate entities pay a minimum effective tax rate of 15% on their profits in every jurisdiction where they conduct operations.
- Affected businesses must submit formal corporate notifications, file relevant MTT returns, and settle any minimum top-up tax liabilities due to avoid administrative penalties or compliance bottlenecks.
