The Kenya Revenue Authority (KRA) has set both the Fringe Benefit Tax (FBT) market interest rate and the deemed interest rate at 9% for October, November and December 2026, up from 8% in the July to September quarter. A 15% withholding tax continues to apply to deemed interest.

Fringe Benefit Tax (FBT)

Section 12B of the Income Tax Act has governed FBT since 12 June 1998. It applies where an employer lends to an employee, a director or their relative at an interest rate below the market rate. The taxable benefit is the difference between interest at KRA’s market rate and the interest the borrower actually pays, and the employer pays the tax on it.

Deemed interest

Section 16(2)(ja), read with the definition of deemed interest in section 2 of the Income Tax Act, applies where a non-resident provides or secures an interest-free loan for a Kenyan resident. The Kenyan borrower is treated as paying interest at KRA’s prescribed rate, and must withhold 15% tax on that deemed interest.

Comparing the two taxes

Fringe Benefit TaxDeemed interest
Typical situationLow-interest loan to an employee, director or their relativeInterest-free loan provided or secured by a non-resident for a Kenyan resident
Q4 2026 benchmark rate9%9%
Tax calculationInterest benefit × FBT rate (the corporation tax rate, 30%)Deemed interest × 15% withholding tax
Who accounts for the taxThe employerThe Kenyan borrower, as withholding agent
Payment deadline9th day of the following monthWithin 5 working days

Comparison by Edward Chebii, CPA, Partner, Tax & Financial Advisory.

Sources: KRA public notice, Fringe Benefit Tax and Deemed Interest Rate, 22 October 2026 · KRA, Understanding Fringe Benefit Tax · Kenyans.co.ke, KRA Announces New 9 Per Cent Tax Rate for Employers and Businesses for Next 3 Months, 22 October 2026.

This briefing is general information, not advice. Contact the partners about your situation.