The Minimum Top-Up Tax (MTT) was introduced under section 12G of the Income Tax Act (Cap. 470) via the Tax Laws (Amendment) Act, 2024. Subsequently, the Income Tax (Minimum Top Up Tax) Regulations, 2026 were developed and published via Legal Notice No. 189 on 18th September, 2026. These regulations are intended to operationalize the MTT provision.
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 the Legal Notice No. 189 of 2026.
Specifically, covered persons are required to -
- Notify the Commissioner of being in scope including, the group name, Country of Ultimate parent Entity and a listing of Constituent entities in Kenya with their PIN numbers. The notification should reach the Commissioner not later than 30th November, 2026 through the following email: mttsupport@kra.go.ke;
- File return for declaration of MTT and pay any minimum top up tax due; and
- Adhere to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.
For any clarification and further guidance you may reach us on email : mttsupport@kra.go.ke
Commissioner for Large and Medium Taxpayers
