KRA has set November 30, 2026, as the deadline for qualifying multinationals to declare their tax status.
KRA directs qualifying multinational companies to declare their tax status by November 30, 2026, and file returns and pay any additional tax due.
The Kenya Revenue Authority (KRA) has given qualifying multinational companies 21 days to declare their Minimum Top-Up Tax status. The notice sets November 30, 2026, as the deadline for notifying the Commissioner.
In its November 9 notice, KRA directed affected businesses to identify their multinational group and its Kenyan entities. The regime aims to ensure large multinational companies pay at least 15 per cent tax on their profits.
Who falls under the Minimum Top-Up Tax?
The tax covers multinational groups with combined annual revenue of at least Ksh110 billion. A group must meet that threshold in at least two of the previous four financial years.
However, a Kenyan subsidiary does not need to reach Ksh110 billion in revenue on its own. It could fall within the regime if the wider multinational group meets the revenue threshold.
For their status declarations, affected companies must provide the group name and the country of the ultimate parent entity. They must also list all constituent entities operating in Kenya, together with their KRA PINs.
The notification requirement therefore concerns both the multinational group’s identity and the details of its Kenyan operations.
Returns, payments and information sharing
Beyond declaring their status, covered companies must file returns and pay any minimum top-up tax due. Where their effective tax rate falls below 15 per cent, they may need to pay additional tax. However, adjustments under the regulations apply when determining the amount needed to cover the difference.
KRA also directed affected businesses to comply with the Multilateral Competent Authority Agreement on the Exchange of GloBE Information. That agreement allows tax authorities in different countries to share information about multinational businesses.
The Tax Laws (Amendment) Act, 2024, introduced the tax by adding Section 12G to the Income Tax Act. KRA subsequently issued implementation regulations in 2026.
Legal Notice Number 189, published on September 18, 2026, set out the implementation framework. It also outlined the obligations of companies covered by the law.
