Kenya has formally aligned with the global push for a 15% minimum effective tax rate on large multinational groups. The Domestic Minimum Top-Up Tax was introduced through the Tax Laws (Amendment) Act 2024 (Act No. 12 of 2024) and took effect on 1 January 2025. The Finance Act 2025 (Act No. 9 of 2025) then added the payment framework, and the KRA published draft computational regulations in November 2025.
Who Is in Scope?
Under Section 12G of the Income Tax Act, the DMTT applies to a ‘covered person’ — a resident or permanent establishment in Kenya that is a member of a multinational group with consolidated annual revenues of at least EUR 750 million in at least two of the four preceding years of income. Where the group meets this threshold, the DMTT ensures that profits taxed in Kenya are subject to a minimum effective rate of 15%. Where the combined effective tax rate on Kenyan profits falls below that level, the DMTT tops it up to 15%.
The Payment Deadline
Under Section 12G(3A), DMTT is due by the end of the fourth month after the close of the year of income. For groups with a December financial year-end, the first DMTT payment covering the year ended 31 December 2025 was due by 30 April 2026. Groups that missed that deadline should address their position without further delay to limit exposure to penalties and interest.
Interaction with Existing Incentives
Where a group benefits from preferential rates such as the SEZ rate or the NIFC rate, those incentives may reduce the combined effective tax rate below 15%, potentially triggering a DMTT top-up. The incentive does not disappear, but its net benefit after DMTT is reduced. Groups relying on tax incentive regimes need to model the DMTT interaction carefully before drawing conclusions about their effective tax cost in Kenya.
Action Points
- Confirm whether your group meets the EUR 750 million consolidated revenue threshold in at least two of the four preceding years of income.
- Model your combined effective tax rate on Kenyan profits to determine whether a top-up liability arises and quantify the amount.
- Ensure your global Pillar Two compliance process captures Kenya in its jurisdictional sweep.
- Review the Draft Income Tax (Minimum Top-Up Tax) Regulations 2025 published by KRA for computational guidance on adjusted covered taxes, net income or loss, and excess profit calculations.
- If the April 2026 payment deadline was missed, seek advice on voluntary disclosure options to limit penalty exposure.
Intelpoint Consulting assists multinational groups with DMTT modelling, compliance structuring, and analysis of interactions with other Kenyan tax obligations. Get in touch if you need clarity on your position.
Contact Intelpoint Consulting: www.intelpointconsulting.com and at info@intelpointconsulting.com