The Kenya Revenue Authority (KRA) has issued a public notice inviting members of the public, professionals, and stakeholders to submit their comments on two new draft income tax regulations for 2025.
In a notice released on November 3, 2025, the Commissioner General of KRA announced the publication of the Draft Income Tax (Advance Pricing Agreement) Regulations, 2025, and the Draft Income Tax (Minimum Top-Up Tax) Regulations, 2025.
The Authority explained that the drafts were developed “in compliance with the Statutory Instruments Act, Cap. 2A,” and in consultation with the Cabinet Secretary for the National Treasury and Economic Planning.
“The Commissioner General, on behalf of the Cabinet Secretary, the National Treasury and Economic Planning, has developed the following regulations: 1. The draft Income Tax (Advance Pricing Agreement) Regulations, 2025, and 2. The draft Income Tax (Minimum Top Up Tax) Regulations, 2025,” KRA stated in the notice.
KRA further emphasized that the initiative aligns with Article 201 of the Constitution, which upholds principles of openness, accountability, and public participation in financial matters.
The public has been encouraged to access the draft regulations, which have been posted on the KRA website, and submit written feedback for consideration in finalizing the regulations.
“In compliance with the same Act and Article 201 of the Constitution, the Commissioner General, on behalf of the Cabinet Secretary, invites interested members of the public, professionals, and stakeholders to submit their inputs and comments for consideration in finalising these Regulations,” the notice added.
According to KRA, the submission window will remain open until Tuesday, December 2, 2025, providing one month for the public to review the documents and give feedback.
The statement further noted that the draft regulations aim to strengthen Kenya’s income tax administration, especially regarding international business transactions and corporate taxation compliance.
Advance Pricing Agreements (APA) are key tools used globally to prevent tax disputes between multinational enterprises and tax authorities by setting pre-determined transfer pricing methods.
Meanwhile, the Minimum Top-Up Tax seeks to ensure that corporations, particularly multinationals, pay a fair share of tax in Kenya, aligning with the country’s domestic and international tax obligations.
While KRA did not elaborate on specific provisions within the notice, the call for public feedback reflects its ongoing effort to engage with the business community and other stakeholders before implementing new fiscal measures.
The Authority reassured the public that the process remains fully open and compliant with Kenya’s legislative requirements on stakeholder engagement.
“You may download the draft regulations for your reference,” the statement said, adding that all submissions received before the December 2 deadline will be reviewed and incorporated where appropriate.
