Kenya Revenue Authority issues fresh compliance directive requiring covered multinational groups to disclose their ownership structures, file tax returns and pay any Minimum Top-Up Tax due.
The Kenya Revenue Authority (KRA) has given multinational corporate groups operating in Kenya until November 30, 2026, to declare their status under the country’s Minimum Top-Up Tax regime, warning that businesses covered by the new rules must meet strict reporting and payment obligations.
In a public notice dated November 9, 2026, KRA directed all taxpayers falling within the scope of the Minimum Top-Up Tax (MTT) to notify the Commissioner of their status, disclose their multinational group structures and comply with the relevant tax regulations.
The directive places November 30 at the centre of a new compliance exercise targeting businesses covered by Section 12G of the Income Tax Act, Cap. 470, and the Income Tax (Minimum Top Up Tax) Regulations, 2026.
KRA said affected taxpayers must submit their notifications by email to [email protected] before the deadline.
What KRA wants multinational companies to submit
According to the tax authority, companies covered by the Minimum Top-Up Tax rules must provide specific information to the Commissioner.
The required disclosure must include:
- The name of the multinational group.
- The country of the Ultimate Parent Entity.
- A list of constituent entities operating in Kenya.
- The Kenya Revenue Authority Personal Identification Numbers (PINs) of the constituent entities.
KRA stressed that the information must reach the Commissioner no later than November 30, 2026.
The authority stated in its notice that covered persons are required to “notify the Commissioner of being in scope”, alongside providing the relevant group and entity information.
The notification requirement is part of a wider compliance framework that also requires affected taxpayers to declare their Minimum Top-Up Tax obligations and settle any tax payable.
KRA demands MTT returns and payment
Beyond the initial notification, KRA has instructed covered persons to file returns declaring their Minimum Top-Up Tax and pay any amount due.
The notice makes clear that notifying the Commissioner is not the only compliance requirement.
Affected businesses must also fulfil their tax declaration and payment obligations under Section 12G of the Income Tax Act and the 2026 regulations.
KRA further directed covered persons to adhere to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.
This requirement connects Kenya’s domestic Minimum Top-Up Tax compliance framework with the international exchange of tax information under the Global Anti-Base Erosion (GloBE) framework.
Why Kenya introduced the Minimum Top-Up Tax
The Minimum Top-Up Tax was introduced through Section 12G of the Income Tax Act under the Tax Laws (Amendment) Act, 2024.
The government subsequently developed the Income Tax (Minimum Top Up Tax) Regulations, 2026, which were published through Legal Notice No. 189 on September 18, 2026.
KRA says the regulations were developed to operationalise the Minimum Top-Up Tax provision.
The framework is associated with the global minimum tax initiative under the OECD/G20 Inclusive Framework, which seeks to ensure that large multinational enterprises are subject to a minimum effective tax rate of 15 per cent in jurisdictions where the relevant rules apply.
The policy is designed to reduce incentives for multinational groups to shift profits into low-tax jurisdictions and strengthen the taxation of large international businesses.
However, the specific application of the Kenyan rules depends on whether a taxpayer meets the statutory conditions for being covered by the regime.
Not every business operating in Kenya should automatically assume that it falls within the MTT framework.
What happens before the November 30 deadline?
With the deadline approaching, multinational groups with Kenyan operations should establish whether they qualify as covered persons and ensure their reporting information is ready.
The immediate priority is to identify the relevant group structure, establish the country of the Ultimate Parent Entity and compile the details and KRA PINs of all constituent entities in Kenya.
Covered taxpayers should then submit their notification to the Commissioner through the designated KRA email address.
They must also assess their return-filing and payment obligations and ensure compliance with the applicable GloBE information exchange requirements.
KRA has provided a dedicated email address for clarification and further guidance: [email protected].
KRA’s latest notice to taxpayers
The Commissioner for Large and Medium Taxpayers issued the November 9 announcement.
It reinforces the tax authority’s implementation of the Minimum Top-Up Tax framework following the publication of the 2026 regulations.
For affected multinational groups, the November 30 deadline is particularly important because it sets a specific date by which the Commissioner must receive the initial notification.
Businesses seeking clarification can contact KRA through [email protected] or visit the authority’s official website at www.kra.go.ke.
