KRA’s 9 November notice directs covered persons to notify the Commissioner by 30 November 2026. The notice does not expressly amend regulation 27’s 60-day rule, which computes to 17 November from publication of Legal Notice 189.
On November 3, 2025, Kenya issued the Draft Income Tax (Minimum Top Up Tax) Regulations, 2025 to provide for the detailed application of the Pillar 2 domestic minimum tax.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Kenya for accounting periods beginning on or after January 1, 2025. Updated for the draft Regulations issued on November 3, 2025.
On December 13, 2024, the Tax Laws (Amendment) Act, 2024 was published in the Official Gazette. It comes into force on December 27, 2024 and includes a domestic minimum top-up tax.
On May 13, 2024, the Finance Bill, 2024 was sent to the Kenyan Parliament. It includes provisions to introduce a 15% domestic minimum top-up tax from January 1, 2025.
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