Multinationals face November 30 deadline for KRA minimum Top-Up Tax compliance

The Kenya Revenue Authority (KRA) has rolled out sweeping new compliance requirements targeting businesses that fall within the scope of the Minimum Top-Up Tax (MTT).

In an official public notice issued on November 9, 2026, the tax authority directed all covered taxpayers to disclose their multinational group structures, file relevant MTT returns, and settle any minimum top-up tax liabilities due.

This directive forms a core pillar of Kenya's broader strategy to align its corporate tax framework with evolving global standards.

According to KRA, affected entities must also fully comply with international information exchange requirements mandated under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.

"The Kenya Revenue Authority therefore wishes to inform all taxpayers who are in scope of the MTT to ensure full compliance with section 12G of the Income Tax Act and the Legal Notice No. 189 of 2026," part of the official statement read.

Under the newly instituted directive, businesses covered by the MTT framework face a strict deadline. They must submit a formal notification to the Commissioner by November 30, 2026.

This mandatory notification requires comprehensive corporate disclosures, including:

The official name of the multinational group.

The home country of the Ultimate Parent Entity (UPE).

Detailed operational information of all constituent entities operating within Kenya, complete with their respective Personal Identification Numbers (PINs).

To streamline the submission process, the KRA has designated mttsupport@kra.go.ke as the official, dedicated email channel for businesses to submit the required group structures and disclosures.

Tax authorities have urged affected corporations to act promptly to avoid administrative penalties or compliance bottlenecks ahead of the approaching deadline.

The Minimum Top-Up Tax is rooted in the landmark international tax reform initiative developed through the Organisation for Economic Co-operation and Development (OECD) and G20, widely known as Pillar Two.

The international framework is specifically engineered to target large multinational enterprise groups that command consolidated annual revenues of at least €750 million in at least two of the preceding four fiscal years.

According to KRA, the primary objective of the Pillar Two framework is to ensure that these large corporate entities pay a minimum effective tax rate on their profits in every jurisdiction where they conduct operations.

The global minimum effective tax rate is standardized at 15% for multinational groups falling within its scope.

However, where the applicable effective tax rate within a specific jurisdiction drops below this minimum threshold, an additional top-up tax arises. The authority emphasizes that these additional tax obligations are subject to local domestic legislation and strict calculation guidelines.

Domestically, the Minimum Top-Up Tax was initially established under Section 12G of the Income Tax Act (Cap. 470) via the Tax Laws (Amendment) Act, 2024.

While the statutory foundation was laid in 2024, the operationalization of the framework required detailed administrative and regulatory mechanisms. To bridge this gap, the Income Tax (Minimum Top-Up Tax) Regulations, 2026 were formally developed and published under Legal Notice No. 189 on September 18, 2026.

KRA reiterated this timeline, stating, “The Minimum Top-Up Tax (MTT) was introduced under section 12G of the Income Tax Act (Cap. 470) via the Tax Laws (Amendment) Act, 2024. Subsequently, the Income Tax (Minimum Top Up Tax) Regulations, 2026 were developed and published via Legal Notice No. 189 on 18th September, 2026.”