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Kenya: Final regulations under Pillar Two law

Final regulations generally follow draft regulations published on October 24, 2025, but also introduce important changes and clarifications.

October 13, 2026

The final regulations under Kenya’s minimum top-up tax (MTT)—which were published on September 18, 2026, as Legal Notice No. 189—provide the detailed framework for implementing Kenya’s MTT, including computation of net income or loss, adjusted covered taxes, substance-based income exclusion, safe harbors, notification filing obligations, and transitional rules.

Under Kenya’s Pillar Two law, the OECD’s global anti-base erosion (GloBE) model rules and agreed administrative guidance may be applied in interpreting the regulations, and covered persons may make relevant GloBE elections not otherwise provided for in the law or regulations.

The final regulations generally follow the draft regulations published on October 24, 2025, but also introduce important changes and clarifications to the operation of the MTT.

Read an October 2026 report prepared by the KPMG member firm in Kenya

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