KRA notice sets 30 November MTT notification date

The notice asks for group and entity details

KRA’s notice says the minimum top-up tax was introduced by section 12G of the Income Tax Act and that the Income Tax (Minimum Top-Up Tax) Regulations, 2026 were published as Legal Notice No. 189 on 18 September. It directs covered persons to notify the Commissioner by 30 November 2026, identifying the group name, the country of the ultimate parent entity and each Kenyan constituent entity with its PIN. The notice gives mttsupport@kra.go.ke as the submission and clarification address.^[1]

Returns and payment are separate obligations

The notice separately tells covered persons to file an MTT return, pay any top-up tax due and comply with the Multilateral Competent Authority Agreement on the Exchange of GloBE Information. It does not state the return due date. Section 12G provides for MTT where a covered person’s combined effective tax rate for the year is below 15%, and subsection 3A requires payment by the end of the fourth month after the year of income.^[1][2][3]

Do not infer that the notice extends every legal deadline

The official KRA notice expressly states 30 November for the notification. The full text of Legal Notice No. 189 could not be read in this run, while current specialist summaries attribute a 60-day initial-notification rule to regulation 27. The notice does not say it amends or extends that regulation. Affected groups should therefore obtain the primary regulation, reconcile the dates immediately and seek KRA clarification rather than assume the later date displaces an earlier statutory deadline.^[1]

Kenyan constituent-entity data should be assembled now

MNE tax teams with Kenyan constituent entities should assemble the group name, ultimate-parent jurisdiction and local PIN schedule and determine whether the group is a covered person under section 12G and Legal Notice No. 189. The existence of a Kenyan entity does not itself establish liability or an amount due. Revenue scope, group structure, exclusions, any safe harbours and the actual effective tax rate remain matters for the legislation, regulations and group facts.^[1][2]