The Kenya Revenue Authority (KRA) has invited public participation in the development of two key tax regulations aimed at enhancing compliance and aligning Kenya’s income tax framework with international standards.
In a public notice issued , the Commissioner General announced that the Authority, on behalf of the Cabinet Secretary for the National Treasury and Economic Planning, had developed the Draft Income Tax (Advance Pricing Agreement) Regulations, 2025 and the Draft Income Tax (Minimum Top-Up Tax) Regulations, 2025.
“In compliance with the Statutory Instruments Act, Cap. 2A, the Commissioner General on behalf of the Cabinet Secretary, the National Treasury and Economic Planning, has developed the following regulations,” the notice read.
The Advance Pricing Agreement Regulations are designed to address transfer pricing issues, offering multinational enterprises a framework for determining appropriate pricing for transactions between related entities.
The Minimum Top-Up Tax Regulations, on the other hand, seek to implement a minimum tax threshold in line with global tax reforms to curb profit shifting and ensure fair taxation.
KRA said the draft regulations have been posted on its website for public review. The Authority is now calling on “interested members of the public, professionals, and stakeholders to submit their inputs and comments for consideration in finalising these regulations.”
Submissions are to be addressed to the Commissioner General, Kenya Revenue Authority, via P.O. Box 48240-00100, Nairobi, or emailed to stakeholder.engagement@kra.go.ke, to be received on or before Tuesday, 2nd December 2025.
