The Kenya Revenue Authority (KRA) has given large multinational companies operating in Kenya 21 days to declare whether they are covered by the Minimum Top-Up Tax (MTT). In a public notice dated Monday, November 9, KRA set a November 30, 2026 deadline for covered firms to notify the Commissioner.
The notification must name the multinational group and the country of its ultimate parent company. It must also list every related company operating in Kenya, with its KRA PIN. According to the Eastleigh Voice, firms must send the details to a dedicated KRA email address. Covered firms must also file MTT returns and pay any top-up tax due. In addition, they must comply with the Multilateral Competent Authority Agreement on the Exchange of GloBE Information. That agreement lets tax authorities in different countries share information about multinational businesses.
The tax applies to multinational groups with combined annual revenue of at least €750 million in at least two of the previous four financial years. Kenyans.co.ke put this at Ksh110 billion, while the Eastleigh Voice put it at about Sh112 billion. A Kenyan subsidiary could be caught even if its own revenue is far smaller, as long as its wider group meets the threshold, Kenyans.co.ke reported. The rule covers resident entities and permanent establishments in Kenya. Public entities that do no business are exempt.
The aim is a minimum effective tax rate of 15 per cent on profits in every country where these groups operate. Kenya's standard corporate tax rate is 30 per cent. However, the Eastleigh Voice noted that some multinationals pay less because of incentives. These include Special Economic Zone and Export Processing Zone benefits, accelerated investment allowances and income exemptions. A firm paying an effective rate of 12 per cent, for example, would owe an extra three per cent.
In its notice, KRA said that all taxpayers within the scope of the MTT must ensure full compliance with the law. According to Pulse Live Kenya, the taxman urged affected firms to act quickly to avoid penalties.
The tax was introduced by adding Section 12G to the Income Tax Act through the Tax Laws (Amendment) Act, 2024. The regulations that put it into effect were published as Legal Notice No. 189 on September 18, 2026. The Eastleigh Voice reported that the tax applies to years of income starting on or after January 1, 2025. The framework stems from the OECD and G20 global tax reform known as Pillar Two. It aims to stop multinationals from shifting profits to low-tax countries.