Mineral tax, royalties and fiscal terms: the mining royalty and the tax on raw exports under Law N° 056/2024, norm value and gross value, who withholds and when to pay, exemptions and affiliate sales, corporate income tax, VAT and capital gains for mining companies, Investment Code incentives and the State's equity

Two taxes on the sale of minerals

Rwanda taxes minerals under Law N° 056/2024 of 26/06/2024 establishing tax on minerals (the Minerals Tax Law). The Chamber of Deputies adopted it at its sitting of 24 May 2024, it was published in the Official Gazette n° Special of 05/07/2024 and, under Article 15, came into force on publication on 5 July 2024, three weeks before the new Mining Law. Article 14 repealed Law N° 55/2013 of 02/08/2013 on minerals tax. Article 13 records that the Law was drafted in English and considered and adopted in Ikinyarwanda. Article 46 of Law N° 072/2024 of 26/06/2024 on mining and quarry operations simply requires mining and quarry licence holders to pay taxes and fees under the relevant legislation.

The "tax on minerals" means the mining royalty tax or the export tax imposed on the value of minerals produced in a Rwandan mine (Article 2(n)). Under Article 3 the person who sells minerals pays the tax. Every category of mineral bears the royalty under Article 4; minerals "exported in raw form" bear the export tax under Article 5 "in addition". According to the Rwanda Revenue Authority (RRA), the 2013 law charged 4% on base metals, 6% on gold and 6% of gross value on precious stones, at a single tax point on export. The 2024 Law cuts the headline rates, collects the royalty at local purchase by a processor as well as at export, and adds a tax on raw exports that processed minerals do not bear. The rates in the table below have not been amended since July 2024.

Norm value, gross value and RMB's role

Most rates apply to the norm value: the value of the minerals on the international market at the date the dealer is granted a certificate for their sale, excluding processing costs approved by the competent authority (Article 2(b)). The international market value is the price set by a recognised global minerals pricing platform (Article 2(i)), and the grade is the measured mineral content with reference to the payable factors in the form in which the mineral is sold (Article 2(j)). The royalty on gemstones is instead charged on gross value, the value of the minerals before deducting the expenses of processing them in a local mineral processing facility (Article 2(a)). The competent authority is the State organ in charge of minerals, the Rwanda Mines, Petroleum and Gas Board (RMB).

Under Article 9 RMB determines the grade, value and processing charges for minerals, and a regulation of RMB is to establish the mechanism for doing so. No regulation made under Article 9(2) appears on RMB's published regulations page, so the values are fixed through RMB's certification of each lot before export, recorded in its Mineral Certification Information System (MCIS). A taxpayer that disagrees with the grade or value used should raise it with RMB before the export declaration, because the tax falls due at that point, and may then challenge any resulting assessment under the tax procedures law (Tax administration, audits and disputes).

Two drafting points do not change the result. Cobalt and manganese appear in both the base metals list and the energy minerals list, but both categories carry 3% royalty and 2% export tax, so the double listing makes no difference. Niobium, which occurs with tantalum in coltan, is a base metal. Uranium and thorium are rare earth elements for this Law, although their mining needs the special radioactive minerals licence under the Mining Law.

Who pays, who withholds and when

Although the seller is the taxpayer, the Law collects the royalty through the buyer. Under Article 6(1) a local mineral processing facility, meaning a facility licensed by RMB for mineral processing (Article 2(o)), or a person who exports minerals from Rwanda must withhold the mining royalty, declare it and remit it to RRA. Where the miner and the exporter are the same operator, there is no withholding: the exporter pays both the royalty and the export tax itself (Article 6(2)).

Under Article 8 the tax on minerals is due on the date of export or the date on which the minerals were bought by a local mineral processing facility, and the date of the customs export declaration is the date of export. Under Article 10 the taxpayer declares and pays the export tax before the minerals are exported, and declares and pays any royalty it has withheld within 15 days following the month in which it was withheld. A sale between licensed traders inside Rwanda is not itself a tax point under Article 8; the royalty is withheld when the minerals reach a local processor or leave the country, and the exporter at that stage must account for it. Traders should therefore agree in their purchase contracts who bears the royalty that the exporter will withhold.

Late declaration or payment brings the ordinary consequences of Law N° 020/2023 of 31/03/2023 on tax procedures: interest of 0.5% to 1.5% a month, capped at the amount of the tax, and fines for late or incorrect declarations. Under the Mining Law, failing to pay sums due is also a ground for provisional suspension of the licence (Article 52(a)).

From mine to export: how the tax on minerals is collected

1. Production and taggingThe miner records production and, for 3T minerals and gold, tags each lot under the traceability system; see 3T, gold and traceability.
2. Sale to a processor or traderIf a licensed local processing facility buys, it withholds the royalty at the date of purchase (Articles 6 and 8). If a licensed trader buys for export, the royalty will be withheld on export.
3. Grade and valueRMB determines the grade, value and processing charges (Article 9); the norm value is the international market value at the date of the sale certificate, less approved processing costs.
4. Export certificateThe exporter applies through MCIS for a Mineral Export Certificate or an ICGLR certificate, and submits a sample to RMB or a designated laboratory.
5. Export tax before exportFor minerals exported in raw form, the exporter declares and pays the export tax before the minerals leave Rwanda (Article 10(1)); the customs export declaration date is the tax point.
6. Remit the royaltyThe processor or exporter declares and pays the royalty it withheld within 15 days after the month of withholding (Article 10(2)); a miner exporting its own minerals pays the royalty itself.
7. Keep the recordsRetain sale certificates, assay reports, customs declarations and payment receipts for RRA and RMB; processors and traders must keep them under Regulations N° 003/MINES/RMB/2019.

Exemptions, affiliate sales and anti-avoidance

Article 7 provides two exemptions. Samples of minerals exported for essay, analysis or other examination are exempt, within a quantity fixed by RMB regulation (Article 7(1)); the 2019 RMB Regulations on samples and the mineral sample permit issued through GIMCS govern the quantities. And processed minerals, and imported minerals to be re-exported, except gold, are exempt from tax on minerals at the export point (Article 7(2)). A smelter or refinery that buys concentrate from Rwandan miners therefore withholds the royalty on its purchase but pays no export tax when it exports metal, while an exporter of raw concentrate pays both. Imported gold re-exported from Rwanda is not exempt, so a refiner of imported gold pays the tax on minerals at export, a rule that ties in with the scrutiny of gold flows discussed in 3T, gold and traceability.

Article 11 requires the holder of a mining licence or a licence to sell minerals to sell to affiliated companies only at a price at least equal to what it would obtain in arm's length sales to non-affiliated purchasers, on terms that would be agreed regardless of affiliation. Where it sells below the international market value, RMB and RRA may use the international market value to determine the value. Article 12 lets RRA disregard, combine or recharacterise a tax avoidance arrangement, disregard a person facilitating it, treat related persons as one, and reallocate income or expenditure. A tax avoidance arrangement includes one whose sole or main purpose is a tax benefit, one carried out in a way not normally used for genuine business purposes, and one creating rights and obligations not normally created at arm's length (Article 2(k)). Offtake agreements with a parent company or trading affiliate abroad should therefore be priced by reference to a recognised benchmark, and documented under the transfer pricing rules in Ministerial Order N° 003/26/10/TC of 29/04/2026 (Transfer pricing and international tax).

Not deductible: the interaction with income tax

Article 6(3) states that the tax on minerals "is not an accepted deductible expense or an advance on income tax in the determination of taxable base for income tax". A mining or trading company therefore pays corporate income tax on its profit computed before the royalty and export tax, and cannot credit them against its corporate income tax liability. That is a significant change from the general rule that business taxes are deductible, and it makes the effective burden of the mineral tax higher than its headline rate: each RWF 100 of royalty costs RWF 100 and saves no income tax.

Corporate income tax is charged at 28% under Law N° 027/2022 of 20/10/2022 establishing taxes on income, as amended by Law N° 051/2023 of 05/09/2023 (Corporate income tax). Losses carry forward for five tax periods, but the Annex to Law N° 006/2021 of 05/02/2021 on Investment Promotion and Facilitation (the Investment Code) allows a registered investor holding an exploration licence to carry losses forward for ten years where its exploration expenditure is at least 50% of its total expenditure (FAQ 107). The general limits apply to mining groups as to others: related-party management, technical and royalty fees are deductible only up to 2% of turnover, interest on related-party loans is not deductible beyond four times paid-up equity, and a change of more than 25% in the ownership of an unlisted company cancels its carried-forward losses. Payments to non-resident drilling, assay, engineering and consultancy firms bear 15% withholding tax unless a treaty reduces it (Withholding taxes and tax treaties).

Neither the Mining Law nor the Minerals Tax Law offers fiscal stabilisation, and no published model agreement under Regulations N° 004/MINES/RMB/2019 freezes tax rates. A stability commitment in a negotiated mining agreement would be an unusual term whose effect against a later Act of Parliament is untested in Rwanda, and investors should model the possibility that rates change, as they did in both directions in 2024 and 2025.

VAT, customs and capital gains

Under Article 7 of Law N° 049/2023 of 05/09/2023 establishing value added tax, both exports and minerals sold on the domestic market are zero-rated (VAT and electronic invoicing). A miner selling concentrate to a local smelter or trader therefore charges VAT at 0% and, if registered, recovers the 18% VAT on its inputs. The VAT exemption for industrial machinery, capital assets and raw materials ended on 30 June 2026; since 1 August 2026 RRA's Commissioner General Guidelines for the Implementation of the VAT Deferral Facility have let an eligible taxpayer in mining, mineral exploration or exploitation, natural gas extraction for energy generation or manufacturing defer import VAT on capital goods and machinery in Chapters 84 and 85 of the EAC Common External Tariff, where the VAT on a consignment is at least RWF 10,000,000 and the application is made to the Commissioner for Customs Services before the goods arrive; spare parts and consumables are excluded unless that Commissioner approves, and an application may be accompanied by the RMB licence or certificate (Customs and EAC trade). Mining equipment imported from outside the East African Community bears the Common External Tariff unless an investor exemption applies.

Since 29 May 2025 Law N° 014/2025 of 27/05/2025 has charged capital gains tax at 10% on direct and indirect transfers, in Rwanda or abroad, of shares and of licences, debt instruments, options, guarantees and similar assets. For shares, the Rwandan company whose shareholders change withholds and pays; for a licence, the seller or buyer does; payment is due within 15 days after the month of the transfer. The sale of a foreign holding company that owns a Rwandan licence holder is therefore within the charge, as well as needing RMB's approval as a transfer under Article 16 of the Mining Law (Mining licences and quarry licences; FAQ 25). The Investment Code exempts registered investors from capital gains tax except on commercial immovable property, but how that exemption applies to licence transfers after the 2025 extension has not been clarified by a published ruling (Capital gains, property and other taxes).

Investment Code incentives for mining

Mining sits partly inside and partly outside the incentive regime of the Investment Code. Article 4 of the Code lists mining activities relating to mineral exploration and processing and value addition in mining among the priority sectors, and point XVI of its Annex gives exploration licence holders the ten-year loss carry-forward described above. But the preferential corporate income tax rates for exporters, 25% for a registered investor exporting 30% to 49% of turnover and 15% for one exporting 50% or more, do not apply to exporters of unprocessed minerals (Investment incentives). Together with the export tax on raw exports and the exemption of processed minerals from tax at export, this steers investors towards concentration, smelting and refining in Rwanda. RMB reported in December 2025 that refining of gold, tin and tantalum was already operational in the country.

Whether a particular processing project qualifies for the 15% rate, the seven-year tax holiday for investments of at least USD 50,000,000 in listed sectors, accelerated depreciation or customs exemptions depends on the Annex and on registration with RDB, and should be checked against the investment chapter. At Rwanda Mining Week in December 2025, RMB's Chief Executive Officer called for incentives specific to mining; no amendment to the Investment Code had been gazetted at 10 October 2026.

The State's equity: Articles 48 and 49

Two provisions of the Mining Law give the Government a possible share of projects beyond tax. Under Article 48 the Government may acquire shares in mining or quarry operations on terms agreed with the licence holder. Under Article 49 "the grant of a mining licence may entitle the government with free carried interest", with the number of shares and the modalities to be set by an Order of the Minister in charge of Government investment. That Order had not been published at 10 October 2026, so no free carried interest can yet be imposed as a condition of a licence; but the power exists, and Be Rwanda Wise FAQ 112, which says there is no mandatory Government participation, does not mention it. In practice the Government has taken equity by agreement, most recently in the tungsten venture announced on 14 September 2026, in which Almonty Industries holds 75% and the Government 25% in return for contributing an exploration concession and a processing licence. State participation, mining agreements and community contributions are covered in Mining agreements, local content and community.