Multinational companies and other qualifying taxpayers have been given until November 30, 2026 to declare their position under the Minimum Top-Up Tax (MTT).

Multinational taxpayers are required to inform the Commissioner of their inclusion in the Minimum Top-Up Tax by submitting the following information regarding their multinational groups and activities in Kenya, according to a notice issued on Monday, November 9.

Taxpayers must give the name of the group, the country of ultimate parent entity and a breakdown of the entities in the group and their PINs. Taxpayers must submit this information to mttsupport@KRA.go.ke by November 30.

They are also required to submit returns regarding their Minimum Top-Up Tax obligations and pay the additional tax due. They are also required to comply with international information exchange requirements. Taxpayers must “notify the Commissioner of being in scope” the Minimum Top-Up Tax. This must be done by November 30.

The Minimum Top-Up Tax does not apply to all companies in Kenya. It applies to qualifying multinational groups with consolidated revenues of at least €750 million in two of the four preceding financial years.

This is calculated at group level so even if the Kenyan subsidiary doesn’t have revenues of €750 million it can still be included. This ensures qualifying multinational groups pay at least 15% effective tax rate on their profits in all jurisdictions they operate in. If the effective tax rate of the group in Kenya is below this then additional tax may be applied.

The Minimum Top-Up Tax was introduced in Kenya under Section 12G of the Income Tax Act, which was introduced under the Tax Laws (Amendment) Act, 2024. The government then issued the Income Tax (Minimum Top-Up Tax) Regulations, 2026 under Legal Notice No. 189 on September 18.

The regulations outline how taxable income should be calculated, which taxes apply, and what reporting requirements apply. This is part of a global tax initiative introduced by the Organisation for Economic Co-operation and Development (OECD) and G20. It ensures large multinational companies pay a minimum effective corporate tax rate in all countries they operate in.

KRA’s most recent directive also requires taxpayers to comply with the Multilateral Competent Authority Agreement on the Exchange of GloBE Information. The Authority has encouraged all taxpayers to comply with the requirements outlined in Section 12G and the 2026 regulations.