Minimum top-up tax: KRA gives multinationals until 30 November

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The Kenya Revenue Authority has given multinational groups in scope of the minimum top-up tax until 30 November 2026 to notify the Commissioner who they are. In a public notice dated Monday, 9 November 2026, KRA’s Commissioner for Large and Medium Taxpayers directed covered companies to notify the Commissioner, file a minimum top-up tax return and pay any tax due. The tax is designed so that covered groups face an effective rate of at least 15% on profits made in Kenya.

What the minimum top-up tax notice asks companies to do

According to the KRA public notice, covered persons must do three things:

1. Notify the Commissioner by 30 November 2026 that they are in scope, giving the group name, the country of the ultimate parent entity and a list of every constituent entity in Kenya with its KRA PIN. The notification goes to mttsupport@kra.go.ke.
2. File a return declaring the minimum top-up tax and pay any amount due.
3. Follow the Multilateral Competent Authority Agreement on the Exchange of GloBE Information, the framework tax authorities use to share data on large multinational groups.

The notice does not give a separate filing date for the return or announce a penalty for late notification. KRA said questions should go to the same email address.

Who the minimum top-up tax covers

The tax sits in section 12G of the Income Tax Act (Cap. 470), inserted by the Tax Laws (Amendment) Act, 2024. KRA says the Income Tax (Minimum Top-Up Tax) Regulations, 2026 were published as Legal Notice No. 189 on 18 September 2026 to put the provision into operation. The notice addresses “covered persons” in scope of that section and those regulations. Ordinary SMEs that are not part of an in-scope multinational group are outside the notice’s compliance list.

Why the minimum top-up tax matters

Under the GloBE framework referenced in the notice, if a group’s effective tax rate in a country falls below 15%, a top-up tax brings it up to that floor. Kenya’s section 12G lets KRA collect that top-up locally. Groups whose Kenyan units enjoy incentives, such as special economic zone rates or investment deductions, are the most likely to owe top-up tax once they confirm they are covered persons.

The notice comes as KRA chases revenue. Companies that disagree with an assessment can still use the routes in our guide to KRA alternative dispute resolution. For other filing dates, see our KRA tax deadlines for 2026 and the related Tax Bill fuel VAT story.

Frequently asked questions

What is the deadline to notify KRA under the minimum top-up tax?

Covered companies must notify the Commissioner by 30 November 2026, by email to mttsupport@kra.go.ke.

What rate does the minimum top-up tax target?

It tops up a covered group’s effective tax rate on Kenyan profits to at least 15%, in line with the GloBE rules referenced in KRA’s notice.

Does the minimum top-up tax apply to small businesses?

No. The notice applies to covered persons in scope of section 12G and Legal Notice No. 189, not to ordinary SMEs outside those groups.

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