Kenya’s tax authority has given large multinational groups operating in the country until 30 November 2026 to notify it that they fall under the minimum top-up tax regime, as part of new compliance requirements for big international businesses.

The Kenya Revenue Authority (KRA) issued a public notice on Monday, 9 November 2026, directing covered taxpayers to tell the Commissioner of their status, disclose the structure of their multinational group, file the relevant minimum top-up tax returns and pay any tax due.

The notice was issued by the Commissioner for Large and Medium Taxpayers. Covered businesses must send their notification by email to mttsupport@kra.go.ke before the deadline.

What companies must disclose

The notification must include the official name of the multinational group, the country where its ultimate parent company is based, and a list of every constituent entity operating in Kenya, together with each entity’s KRA Personal Identification Number (PIN).

The 30 November date applies to the notification to the Commissioner. The notice also requires covered taxpayers to file minimum top-up tax returns and settle any tax due, but it does not set 30 November as a single deadline for every return and payment.

Who is covered

The regime does not apply to every business in Kenya. It covers large multinational enterprise groups whose consolidated annual revenue reaches at least €750 million — about Sh112 billion — in at least two of the preceding four financial years, subject to the scope rules and exclusions in the law.

The minimum top-up tax is designed to ensure that qualifying groups pay an effective tax rate of at least 15% on profits earned in Kenya. It follows the OECD/G20 Pillar Two global minimum tax framework, known as the GloBE rules, which aims to stop large multinationals paying very low tax rates by shifting profits between countries.

The legal basis

Kenya introduced the minimum top-up tax through Section 12G of the Income Tax Act (Cap. 470), inserted by the Tax Laws (Amendment) Act, 2024. The rules that put it into operation, the Income Tax (Minimum Top-Up Tax) Regulations, 2026, were published as Legal Notice No. 189 on 18 September 2026.

The tax applies to years of income beginning on or after 1 January 2025. KRA has provided the dedicated mttsupport@kra.go.ke address for questions and guidance, and its large and medium taxpayers department is handling the process.

Businesses covered by the regime that miss the notification deadline risk falling foul of the new compliance requirements, so advisers have urged in-scope groups to check their status and gather the required group information well before 30 November.

Sources: Pulse Kenya and The Eastleigh Voice.