The Kenya Revenue Authority has set an initial notification deadline of 30 November 2026 for in-scope multinational groups under the country's 15% minimum top-up tax regime.
The Kenya Revenue Authority (KRA) has issued a public notice on 9 November 2026 setting 30 November 2026 as the initial deadline for entities subject to the minimum top-up tax to notify the Commissioner under Section 12G of the Income Tax Act (Cap. 470) and the Income Tax (Minimum Top Up Tax) Regulations, 2026.
The Income Tax (Minimum Top Up Tax) Regulations, 2026 were issued under Legal Notice No. 189, dated 18 September 2026.
Earlier, Kenya’s Income Tax (Minimum Top Up Tax) Regulations, 2026 established a 15% minimum effective tax rate on large multinationals in domestic law. The Cabinet Secretary signed them on 12 August 2026, and they were gazetted on 18 September 2026. They follow the OECD Pillar Two GloBE Model Rules and cover income years starting on or after 1 January 2025, so the first in-scope year is already behind us.
The test for coverage is consolidated annual turnover of EUR 750 million or more (or the local currency equivalent) in at least two of the four preceding income years. If a group’s reporting period isn’t 12 months, the threshold is prorated by the number of days in the year. The regulations also set consolidation rules for restructurings, including group mergers and demergers.
Covered entities must notify the Commissioner of their status as in-scope entities by 30 November 2026, providing the group name, the country of the Ultimate Parent Entity, and a list of Kenyan constituent entities with their respective PINs. Notifications must be sent to [email protected]. They must also file the minimum top-up tax return, pay any tax due, and comply with the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.
