Nairobi, Dec. 1 -- When the Kenya Revenue Authority (KRA) released the Draft Income Tax (Advance Pricing Agreement (APA) Regulations, 2025, and the Draft Income Tax (Minimum Top-Up Tax) Regulations, 2025, it signaled a welcome step towards modernising Kenya's international tax framework.

Together, these two instruments seek to align Kenya with the evolving Organisation for Economic Co-operation and Development (OECD) standards, offering clarity on related-party pricing through the APA regime, and implementing the global 15 percent minimum effective tax rate under the GloBE (Global Anti-Base Erosion) model.

For policymakers, the ambition is commendable. But for taxpayers, the details reveal a familiar tension between compliance idealism ...