The Kenya Revenue Authority (KRA), on behalf of the National Treasury and Economic Planning, has issued a public notice inviting members of the public, professionals, and stakeholders to review and submit comments on two new draft tax regulations.
This move is in line with the Statutory Instruments Act, Cap. 2A and Article 201 of the Constitution, which emphasize public participation and transparency in the development of financial and tax-related laws.
Draft Regulations Open for Public Input
The two draft regulations developed under the Income Tax framework are:
- Draft Income Tax (Advance Pricing Agreement) Regulations, 2025
- Draft Income Tax (Minimum Top Up Tax) Regulations, 2025
These regulations aim to modernize Kenya’s income tax framework, promote fairness, and ensure compliance with evolving international tax standards.
Purpose of the Draft Regulations
The Advance Pricing Agreement (APA) Regulations are designed to guide how multinational enterprises can agree in advance with KRA on transfer pricing methods for cross-border transactions.
This will provide greater certainty and predictability in the taxation of multinational operations while reducing the risk of disputes.
On the other hand, the Domestic Minimum Top Up Tax (DMTT) Regulations seek to implement a minimum effective tax rate for large multinational groups operating in Kenya.
This is in line with the OECD/G20 Global Minimum Tax framework (Pillar Two), ensuring that multinational corporations pay a minimum level of tax regardless of where they operate.
Together, these drafts represent Kenya’s continued commitment to international tax reform, transparency, and fair taxation across the digital and global economy.
How to Participate
KRA is calling on Kenyans, professional bodies, businesses, and stakeholders to review the draft regulations and share their comments or recommendations to help shape the final versions.
- Deadline for submissions: Tuesday, 2nd December 2025
- Email submissions to: [email protected]
- Download the draft regulations: Available on the KRA website
You may download the Draft Income Tax (Advance Pricing Agreement) Regulations and Draft Income Tax (Minimum Top Up Tax) Regulations for your reference.
Submissions may also be delivered by post to:
The Commissioner General
Kenya Revenue Authority
P.O. Box 48240-00100, Nairobi.
Public Participation in Tax Reform
Public consultation plays a critical role in ensuring that tax laws are practical, inclusive, and effective. By engaging the public and professionals, KRA and the National Treasury aim to develop well-informed, fair, and enforceable tax regulations that align with Kenya’s economic goals and global standards.
This call for comments underscores the government’s ongoing efforts to strengthen Kenya’s tax administration system through collaboration and open dialogue. Stakeholders are encouraged to take part in this process before the 2nd December 2025 deadline.
Matthews Ohotto is an Article Writer at CYBER.CO.KE and a Video Creator at Cyber Services Kenya (YouTube). He specializes in crafting insightful blog posts and video tutorials that empower Kenyans with practical digital skills and knowledge. Holding a Bachelor’s Degree in Business Information Technology (BBIT) from JKUAT, he combines technical expertise with creative insight.
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