You may have read headlines about a global minimum tax and wondered whether it affects your business. For almost every small and medium business in Kenya the answer is no, but it is a real part of the law for the largest groups, and it changed the way Kenya taxes them.

What it is

Many countries have agreed a framework known as Pillar Two, which aims to make sure that large multinational groups pay at least 15% tax on their profits in every country where they operate. Where the tax paid in a country is lower, a top-up tax brings it up to the minimum.

What Kenya has adopted

Kenya adopted a qualified domestic minimum top-up tax (QDMTT). This means that, where a group's profits in Kenya are taxed below the minimum, Kenya itself collects the top-up, instead of leaving it to another country to do so. According to a summary of the tax rules, only the QDMTT has been adopted so far, and the Finance Act, 2025 repealed the earlier domestic minimum tax and replaced it with the top-up tax.

Who it applies to

The rule applies only to groups with consolidated revenue of at least EUR 750 million in at least two of the four preceding years. Those are the largest multinational groups in the world. A Kenyan company that is not part of a group of that size is not affected, whether it is a sole trader, a family company or a mid-sized firm.

When it is paid

The top-up tax is due by the last day of the fourth month after the end of the financial year being tested. For a group with a December year end, a first payment would have been due by 30 April 2026, with final regulations expected around then. Groups must also file the relevant returns.

What it means for most businesses

If you are a supplier to or part of a large group

You might be asked for information about your tax position by the group's tax team. Your accountant can explain what is needed, and your records should be in order; see how to keep business records for KRA.

Kenya also changed how it taxes large digital platforms; see digital service tax replaced by significant economic presence tax.

Why it matters to the rest of us

The rule shows how the law keeps moving at the top end, and how a headline can reach small businesses as confusion. Know what applies to you, and ignore what does not.

Stay up to date

If you work for or with a large group, follow the regulations; see how to follow tax changes in Kenya.

This is a summary for general information. Groups in scope should take advice from a qualified international tax adviser.