Editor's Review


KRA has announced new tax compliance requirements for multinational companies and other covered taxpayers falling within the scope of the Minimum Top-Up Tax (MTT).

The Kenya Revenue Authority (KRA) announced new tax compliance requirements for multinational companies and other covered taxpayers falling within the scope of the Minimum Top-Up Tax (MTT).

In a notice on Monday, November 9, the authority said the requirements were introduced under Section 12G of the Income Tax Act (Cap. 470) through the Tax Laws (Amendment) Act, 2024, which established the Minimum Top-Up Tax framework.

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Subsequently, the Income Tax (Minimum Top Up Tax) Regulations, 2026 were developed and published through Legal Notice No. 189 on September 18, 2026, to operationalise the MTT provisions.

As such, KRA urged all taxpayers falling within the scope of the tax to comply with the relevant provisions of the law and the newly published regulations.

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"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," the notice read.

KRA outlined three key requirements that covered persons were expected to fulfil, including notifying the Commissioner that they fell within the scope of the Minimum Top-Up Tax.

The notification was required to include the name of the multinational group, the country of its Ultimate Parent Entity and a list of its constituent entities operating in Kenya, alongside their respective Personal Identification Numbers (PINs).

The authority directed affected taxpayers to submit the information through the email address [email protected], with the deadline set for November 30, 2026.

Additionally, covered persons were required to file returns declaring their Minimum Top-Up Tax obligations and pay any tax due under the provisions.

They were also required to adhere to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information as part of the compliance requirements.

File image of KRA offices

Meanwhile, KRA has excluded 30 categories of goods from its consolidated cargo clearance framework for consignments valued under Ksh2 million.

In a notice on Friday, November 6, the authority clarified that while the framework allows the consolidation of certain goods, specific products have been excluded, while others may only be accepted subject to strict conditions on cargo volume, declaration and customs valuation.

KRA stated that the exclusions were intended to guide stakeholders involved in cargo clearance and ensure compliance with the requirements governing the framework.

"Kenya Revenue Authority (KRA) wishes to notify all cargo clearance stakeholders that the items listed below are excluded from the consolidated cargo clearance for consignment under Ksh2 million framework," the notice read.

The excluded items included assorted foodstuff, complete kitchen, designer brands for finished manufactured products, plant and machinery, except small machinery such as handheld tractors and similar small-scale equipment supporting the agricultural and small industry sectors.

Other excluded goods included smartphones and watches, used clothes and shoes, wooden, steel and aluminium doors, televisions, and car accessories.

The car accessories category covered car audio systems, speakers, dash cameras, reversing cameras, parking sensors and GPS navigation devices.

KRA also listed musical instruments, public address systems, entertainment equipment and related accessories, as well as sanitary ware among the items excluded from the framework.

However, the authority clarified that some categories of goods could still be allowed as consolidated cargo provided importers met specific requirements.

These included cables, ready-made garments, fabrics, interlining material, beddings and household linen, carpets, cosmetics, toiletries and beauty products.

The list also covered new motorcycle spare parts and accessories, new shoes, terry towels, auto paints, epoxy and related products, padlocks, curtain accessories, door locks and handles.

Other conditionally accepted items included hardware products such as machetes, meters and valves, bathroom accessories such as towel holders, towel bars and showerheads, cosmetic and haircare products, henna, computer accessories and mobile phone accessories.