Kenya gives multinational groups until 30 November to notify top-up tax

Kenya gives multinational groups until 30 November to notify top-up tax

9 November 2026: The Kenya Revenue Authority has told companies in scope of the country's Minimum Top-Up Tax that they must notify the Commissioner by 30 November 2026, giving the group's name, the country of its ultimate parent entity and every constituent entity in Kenya with its PIN. The notice, issued by the Commissioner for Large and Medium Taxpayers, also asks them to file the MTT declaration return, pay any top-up tax due and follow the multilateral agreement on exchanging GloBE information.

Not yet independently verified. The KRA notice carries no date on the page; we dated it from the KRA public-notices feed (9 November 2026). It does not restate which groups are in scope, the due date for the return or any penalty, and we have not read Legal Notice No. 189 itself. We will update this when it can be confirmed, and remove this note.

Two years from the Act to the deadline

The tax itself is not new. Section 12G was added to the Income Tax Act (Cap. 470) by the Tax Laws (Amendment) Act, 2024. What was missing was the machinery, and that arrived with the Income Tax (Minimum Top Up Tax) Regulations, 2026, published as Legal Notice No. 189 on 18 September 2026 "to operationalize the MTT provision", in KRA's words.

The notice is the first practical step since then. It treats the regulations as in force and moves straight to what covered persons must do, so a group that has been waiting for the rules before acting now has a fixed date.

The three duties KRA lists

KRA asks every covered person to do three things:

• notify the Commissioner of being in scope, with the group name, the country of the ultimate parent entity and a list of the constituent entities in Kenya with their PIN numbers, so that the notification reaches the Commissioner by 30 November 2026 at mttsupport@kra.go.ke;
• file the return declaring the MTT and pay any minimum top-up tax due;
• adhere to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.

The third duty ties Kenya's tax to the OECD's global minimum tax framework, under which the GloBE information return is exchanged between tax authorities. A group that already prepares that return for its parent jurisdiction will hold most of what Kenya asks for.

Where finance teams start

The notification is a short list, but it depends on data that is often spread across systems: the legal entity register, KRA PINs held by local finance teams and the group structure chart kept at headquarters. Groups with several Kenyan subsidiaries, branches or permanent establishments should check that the list of constituent entities matches what the group's GloBE calculation treats as Kenyan.

The notice does not restate the size of group that falls in scope, the date the declaration return is due or the penalty for missing the notification, so those have to be read in Legal Notice No. 189 itself. Groups unsure whether they are covered persons have just over two weeks to settle that before the 30 November date.

Related on TrustList:

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• Qatar gives multinationals until January to register for minimum tax
• Pakistan's FBR moves the 2026 tax return deadline to 31 October

Sources

• Kenya Revenue Authority: Compliance with Section 12G of the Income Tax Act (Cap. 470) and the Income Tax (Minimum Top-Up Tax) Regulations, 2026, 9 November 2026