The Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (MLI) took effect in Kenya on 1 May 2025.
For tax treaties between Kenya and countries where the MLI is already in force, it applies from 1 January 2026 for withholding taxes and from taxable periods starting on or after 1 November 2025 for other taxes.
The Multilateral Instrument (BEPS MLI) offers concrete solutions for governments to close loopholes in international tax treaties by transposing results from the BEPS Project into bilateral tax treaties worldwide. The BEPS MLI allows governments to implement agreed minimum standards to counter treaty abuse and to improve dispute resolution mechanisms while providing flexibility to accommodate specific tax treaty policies.
