| Status | Enacted Law |
| Law | Income Tax (Minimum Top Up Tax) Regulations, 2026 (Legal Notice 189), made 12 August 2026 and published 18 September 2026, provide the final operative rules. Read our analysis of notification, returns and elections. The regime was introduced by the Tax Laws (Amendment) Act, 2024. The 24 October 2025 consultation draft is historical and is not operative. |
| Effective Date | Years of income beginning on or after January 1, 2025 |
| IIR | No |
| UTPR | No |
| QDMTT | Yes (2025). The OECD Updated Central Record current at 1 May 2026 lists Kenya’s Income Tax Act as a qualified domestic minimum top-up tax and records “Yes” for the QDMTT Safe Harbour, effective 1 January 2025. |
| 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. KRA’s public notice dated 9 November 2026 states 30 November 2026 for the initial notification. It does not expressly amend regulation 27(1)’s 60-day period; groups should use the earlier computed 17 November date where possible or obtain written confirmation. |
| 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. |
If you haven’t got a subscription you can sign up below
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution
© 2026 OECDPillars.com
All Rights Reserved