KRA moves to enforce 15 per cent minimum tax on multinational companies

The Minimum Top-Up Tax applies to multinational companies whose combined annual revenue is at least Sh110 billion. [File, Standard]

Kenya Revenue Authority (KRA) has given multinational companies operating in Kenya 21 days to declare whether they fall under a new tax regime requiring large firms to pay a minimum of 15 per cent tax on their profits.

In a notice dated Monday, November 9, KRA directed companies covered by the Minimum Top-Up Tax (MTT) to notify the Commissioner of their tax status by November 30, 2026.

The Authority wants the affected companies to provide details of their multinational groups, including the country where their Ultimate Parent Entity is based and a list of all related entities operating in Kenya, together with their KRA Personal Identification Numbers (PINs).

"Notify the Commissioner of being in scope, including the group name, Country of the Ultimate Parent Entity, and a listing of Constituent entities in Kenya with their PINs," KRA directed.

The Minimum Top-Up Tax applies to multinational companies whose combined annual revenue is at least Sh110 billion in at least two of the previous four financial years.

Besides declaring their tax status, companies falling within the scope of the new regime are required to file Minimum Top-Up Tax returns and pay any additional tax due.

"We therefore wish to inform all taxpayers covered in the scope of the MTT to file a return for declaration of MTT and pay any minimum top-up tax due," the Authority stated.

KRA further directed the affected companies to comply with the Multilateral Competent Authority Agreement on the Exchange of GloBE Information, which provides a framework for tax authorities in different countries to exchange information on multinational businesses.

The tax was introduced through the Tax Laws (Amendment) Act, 2024, which inserted Section 12G into the Income Tax Act.

KRA subsequently issued regulations in 2026 to guide the implementation of the minimum tax regime.