KRA Issues Fresh Notice to Taxpayers on Minimum Top-Up Tax Compliance

The Kenya Revenue Authority (KRA) has issued a fresh notice directing taxpayers covered by the Minimum Top-Up Tax (MTT) to comply with the requirements under the Income Tax Act.
In a notice on Monday, November 9, 2026, the tax authority reminded covered persons to meet their obligations under Section 12G of the Income Tax Act (Cap. 470) and the Income Tax (Minimum Top-Up Tax) Regulations, 2026.
KRA said the MTT was introduced under Section 12G of the Income Tax Act through the Tax Laws (Amendment) Act, 2024.
The authority added that the regulations were subsequently developed to operationalise the tax provision and published through Legal Notice No. 189 on September 18, 2026.
“The Kenya Revenue Authority therefore wishes to inform all taxpayers (Covered Persons) who are in scope of the MTT to ensure full compliance with Section 12G of the Income Tax Act and Legal Notice No. 189 of 2026,” KRA said.
Under the notice, covered persons are required to notify the Commissioner that they fall within the scope of the MTT.
The notification must include the group’s name, the country of the ultimate parent entity and a list of constituent entities in Kenya, together with their Personal Identification Numbers (PINs).
KRA directed that the notification be submitted through the email address mttsupport@kra.go.ke no later than November 30, 2026.
Covered taxpayers are also required to file returns declaring their Minimum Top-Up Tax and pay any tax due.
Additionally, they must comply with the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.
