The consultation is set to conclude on 2 December 2025.  

The Kenya Revenue Authority (KRA) released two draft regulations for public consultation, covering its global minimum tax regime and advance pricing agreement procedures for 2025, on 3 November 2025.

In compliance with the Statutory Instruments Act, Cap. 2A, the Commissioner General, on behalf of the Cabinet Secretary, the National Treasury and Economic Planning, has developed the following draft regulations:

  1. The draft Income Tax (Advance Pricing Agreement) Regulations, 2025
  2. The draft Income Tax (Minimum Top Up Tax) Regulations, 2025

The draft rules provide additional guidance on the application of the minimum top-up tax and outline the process for companies to obtain advance pricing agreements, aimed at preventing future tax disputes.

In compliance with the same Act and Article 201 of the Constitution, the Commissioner General, on behalf of the Cabinet Secretary, the National Treasury and Economic Planning, invites interested members of the public, professionals and stakeholders to submit their inputs and comments for consideration in finalising these Regulations.

The consultation is set to conclude on 2 December 2025.