GloBE Country Guide: Kenya

Summary

Status	Enacted law and final regulations
Law	Income Tax (Minimum Top Up Tax) Regulations, 2026 (Legal Notice 189), made 12 August 2026 and published 18 September 2026. Analysis of the final regulations. Tax Laws (Amendment) Act, 2024 Historical consultation draft: Income Tax (Minimum Top Up Tax) Regulations, 2025
Effective Date	Financial years beginning on or after January 1, 2025
IIR	No
UTPR	No
QDMTT	Yes. The OECD Central Record (current at 1 May 2026, p. 9) lists Kenya’s Income Tax Act with transitional QDMTT status and QDMTT Safe Harbour recognition, effective 1 January 2025. OECD record. This recognition predates the September 2026 final regulations.
Filing Deadlines	Local minimum top-up tax return: six months after year-end. GIR: 18 months for the first year and 15 months thereafter (regulation 28). Payment: four months after year-end under section 12G(3A), separately from filing.
Safe Harbours	Regulation 29 addresses the Transitional CbCR Safe Harbour and Simplified Calculations for Non-Material Constituent Entities, subject to the incorporated conditions. Its July 2029 wording is not unconditional relief for every earlier year.

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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