Chapter 3 of 11
Tax & Compliance
Rwanda taxes companies under a 2022 income tax law, a 2023 VAT law and a 2023 tax procedures law, all reshaped by the package of seven tax laws gazetted on 29 May 2025 and by a run of Ministerial Orders in April and September 2026 on transfer pricing, VAT on online supplies, electronic invoicing, corporate residence and certified accounts. This chapter sets out the rules as they stand at 10 October 2026 for a Rwandan company with foreign or local shareholders, a branch of a foreign company, their suppliers and lenders abroad, and their expatriate and local staff.
At a glance
Governing law
- Law N° 027/2022 of 20/10/2022 establishing taxes on income, as amended by Law N° 051/2023 of 05/09/2023 and Law N° 014/2025 of 27/05/2025
- Law N° 049/2023 of 05/09/2023 establishing value added tax, as amended by Law N° 009/2025 of 27/05/2025
- Law N° 020/2023 of 31/03/2023 on tax procedures
- Ministerial Order N° 003/26/10/TC of 29/04/2026 on transfer pricing, simplified accounting and losses carried forward beyond five tax periods
- Ministerial Orders N° 004/26/10/TC of 29/04/2026 (VAT on online supplies), N° 006/26/10/TC of 24/09/2026 (electronic invoicing) and N° 009/26/10/TC of 24/09/2026 (residence and certified accounts)
- Law N° 011/2025 of 27/05/2025 establishing the excise duty and Law N° 048/2023 of 05/09/2023 on the revenue of decentralized entities
- Law N° 006/2021 of 05/02/2021 on Investment Promotion and Facilitation (tax incentives in the Annex)
Who you will deal with
- Rwanda Revenue Authority (RRA), the "Tax Administration" of the statutes: registration, returns, refunds, electronic invoicing, audits, customs and the collection of District taxes
- Commissioner General of RRA: advance rulings, administrative appeals, extensions and instalment plans
- Ministry of Finance and Economic Planning (MINECOFIN): tax policy, Ministerial Orders and the Tax Policy Committee
- Rwanda Development Board (RDB): the Registrar General issues the taxpayer identification number on registration, and RDB approves investors' customs exemptions
- Districts and the City of Kigali: owners of property tax, rental income tax and trading licence tax, which RRA collects for them
- East African Community Council of Ministers: the Common External Tariff, stays of application and duty remission
Key figures
- Standard corporate income tax rate
- 28% (since 14 September 2023)
- Standard VAT rate
- 18%; registration above RWF 20 million a year or RWF 5 million in a quarter
- Withholding tax on dividends, interest, royalties and service fees
- 15%, unless a treaty caps it lower (for example 7.5% on dividends under the China, Singapore and UAE treaties)
- Capital gains tax on shares
- 10% (5% before 29 May 2025)
- Top PAYE rate
- 30% above RWF 200,000 a month
- Related-party debt and fees
- Interest non-deductible beyond 4:1 debt to equity; fees capped at 2% of turnover
- Accounts certified by an approved professional
- Turnover of RWF 1 billion or more (from 25 September 2026)
- Late-payment interest
- 0.5% to 1.5% a month, capped at 100% of the tax
What changed in 2024–26
- 29 May 2025: Laws N° 009/2025 to N° 015/2025 were gazetted, raising capital gains tax from 5% to 10% and extending the withholding rule, which since 2022 has made the Rwandan company account for the tax on direct and indirect transfers of its shares, to licences, debt instruments, options, guarantees and similar assets, enacting a 1.5% digital services tax whose implementing Order is still awaited, narrowing the VAT exemptions, replacing the excise law and introducing new fuel and vehicle levies.
- 1 July 2025: the 3% tourism tax on accommodation and the 0.2% environmental levy on imports packaged in plastic took effect; since about 29 August 2025, gaming companies pay 40% of wagers less winnings instead of corporate income tax.
- 29 April 2026: Ministerial Order N° 003/26/10/TC rewrote the transfer pricing rules, with a local file, a master file and a 15% beneficial tax regime test, and Ministerial Order N° 004/26/10/TC required non-resident suppliers of online services to register for VAT.
- 30 June 2026: the VAT exemption for industrial machinery, capital assets and raw materials ended, and Ministerial Order N° 004/26/10/TC bars its renewal; from 1 August 2026 RRA's VAT Deferral Facility lets eligible manufacturers and miners defer import VAT on qualifying machinery.
- 25 September 2026: Ministerial Order N° 006/26/10/TC replaced the 2013 electronic billing machine rules, and Ministerial Order N° 009/26/10/TC set a broad effective-management test for corporate residence and a RWF 1 billion turnover threshold for certified accounts.
Who this applies to. Rwanda's tax laws make no distinction by the nationality of a company's owners: a Rwandan company with foreign shareholders pays the same 28% corporate income tax, charges the same 18% VAT, files the same returns and faces the same penalties as one owned by Rwandans. The differences lie in the cross-border flows. Dividends, interest, royalties and service fees paid to a non-resident bear 15% withholding tax unless a treaty reduces it; a branch pays 15% on profits it repatriates; a non-resident selling shares in a Rwandan company pays 10% capital gains tax, withheld by the company; and dealings with foreign group companies fall under the transfer pricing rules. Investors registered with RDB under the Investment Code, whether foreign or Rwandan, may qualify for preferential rates and exemptions, and some withholding tax rates differ for residents of the East African Community.
How Rwanda taxes a business
A company registered in Rwanda is taxed in the same way whoever owns it. It pays corporate income tax on its worldwide profit, charges and recovers value added tax, withholds pay-as-you-earn (PAYE) from its employees and withholding tax from many of its payments, pays customs duties and excise at the border, and pays property tax and trading licence tax to its District. A foreign company that trades in Rwanda through a branch or other permanent establishment pays corporate income tax on the profit of that establishment. There is no separate tax regime for foreign-owned companies; the incentives in the Investment Code are open to any investor registered with the Rwanda Development Board (RDB), foreign or Rwandan.
The national taxes are administered by the Rwanda Revenue Authority (RRA), which the statutes call the Tax Administration, through its e-tax portal. RRA also runs customs and the Electronic Single Window, certifies the electronic invoicing systems every business must use, and collects the decentralised taxes on behalf of the Districts and the City of Kigali. Tax policy, and the Ministerial Orders that fill in the detail of each law, come from the Ministry of Finance and Economic Planning (MINECOFIN). The taxpayer identification number (TIN) is issued by the Registrar General when the company is registered, so tax compliance begins on the day the company exists; the recurring deadlines are gathered in Compliance calendar after registration.
Profits and turnover: corporate income tax and VAT
Corporate income tax is charged at 28% under Article 48 of Law N° 027/2022 of 20/10/2022 establishing taxes on income, as amended by Law N° 051/2023 of 05/09/2023, which cut the rate from 30% and came into force on 14 September 2023. Newly listed companies pay 20% or 25% for five years, deposit-taking microfinance institutions pay 0%, small businesses pay 3% of turnover and micro-enterprises a flat annual amount. Expenses are deductible if incurred for the business, but donations above 1% of turnover, related-party management, technical and royalty fees above 2% of turnover, and interest on related-party loans above four times paid-up equity are not. Losses carry forward for five years. Since 25 September 2026, Ministerial Order N° 009/26/10/TC treats a foreign-incorporated company as resident if any one of four links to Rwanda exists, and requires accounts certified by an RRA-approved professional where turnover reaches RWF 1 billion. See Corporate income tax, and Investment incentives for the preferential rates and tax holidays.
VAT is charged at 18%, or 0% on exports and other zero-rated supplies, under Law N° 049/2023 of 05/09/2023, as amended by Law N° 009/2025 of 27/05/2025, which removed several exemptions and set end dates for others. A business registers once its turnover exceeds RWF 20 million in a year or RWF 5 million in a quarter, files quarterly up to RWF 200 million of turnover and monthly above it, and must issue every invoice from an RRA-certified electronic invoicing system under Ministerial Order N° 006/26/10/TC. Non-resident suppliers of online services must register under Ministerial Order N° 004/26/10/TC, failing which the bank or payment provider withholds the VAT. See VAT and electronic invoicing.
Money leaving Rwanda: withholding tax, treaties and transfer pricing
When a Rwandan company pays dividends, interest, royalties or service fees to a non-resident, it withholds 15% under Article 60 of the income tax law and pays it within 15 days after the month of payment. A branch pays the same 15% on profits it repatriates. Lower rates apply to listed securities held by residents of Rwanda or the East African Community, to Treasury bonds of three years or more, and to some investors registered under the Investment Code. Rwanda's tax treaties, which RRA lists on its website, reduce the rate where the recipient produces a tax residence certificate with the withholding tax return. The rates, exemptions, the mechanics of withholding and the treaty network are in Withholding taxes and tax treaties.
Dealings with related parties must be priced at arm's length. Ministerial Order N° 003/26/10/TC of 29/04/2026 requires a transfer pricing policy, a local file and a master file, extends the rules to any transaction with a person in a regime taxing at 15% or less, requires documentation to be produced within seven days of a request, and offers advance pricing agreements; smaller taxpayers below the thresholds in Article 19 are relieved of the documentation duty but not of the arm's length rule. These rules, and Rwanda's position outside the OECD Inclusive Framework, are covered in Transfer pricing and international tax.
People, assets and goods
Individuals resident in Rwanda, which includes anyone with a permanent residence or habitual abode there or present for 183 days in a tax period, are taxed on worldwide income. Employers withhold PAYE monthly or quarterly at 0%, 10%, 20% and 30%, with the top rate applying above RWF 200,000 a month, and add the value of a company car and housing at 10% and 20% of cash pay. Expatriates are taxed under the same rules as Rwandans, and the employer also pays pension, maternity and occupational hazard contributions to the Rwanda Social Security Board (RSSB). See Personal income tax, PAYE and expatriates.
Capital gains on direct and indirect transfers of shares, in Rwanda or abroad, have been taxed since the 2022 income tax law, with the tax withheld by the Rwandan company whose shareholders change, and since 29 May 2025 the rate is 10% (previously 5%) and the withholding rule also reaches licences, debt instruments, options, guarantees and similar assets; a 1.5% digital services tax has been enacted but awaits its implementing Order; excise duty, tourism tax and a series of levies apply to particular goods and services; and property tax, rental income tax and trading licence tax are paid to the Districts. These are in Capital gains, property and other taxes. Goods imported into Rwanda bear the East African Community Common External Tariff of 0%, 10%, 25% or 35%, together with 18% import VAT and a 5% withholding tax on the CIF value of commercial imports, with exemptions for registered investors processed through the Electronic Single Window: see Customs and EAC trade.
Compliance, audits and disputes
Law N° 020/2023 of 31/03/2023 on tax procedures governs registration, records, assessments, audits, appeals and recovery. Records must be kept for ten years. An audit starts with seven working days' notice and leads to a draft rectification note, to which the taxpayer has 30 days to reply after a comprehensive or transfer pricing audit and five days after an issue-oriented or refund audit. A taxpayer may appeal to the Commissioner General within 30 days of the assessment; if the Commissioner General does not decide within the time the law allows, the appeal is deemed upheld. The case may then go to amicable settlement or to court within 30 days. Late payment carries interest of 0.5% to 1.5% a month, capped at the amount of the tax, and late declaration a fine of 20% to 60% of the tax. The detail is in Tax administration, audits and disputes, and challenges in court are also covered in Regulatory, tax and public law disputes.
How to use this chapter
A new investor should read Corporate income tax and VAT and electronic invoicing first, because registration for both, and the electronic invoicing system, are needed from the first sale. Before agreeing any management fee, loan or licence with a foreign parent, read Withholding taxes and tax treaties and Transfer pricing and international tax together: the 15% withholding tax, the 2% cap on related-party fees, the 4:1 debt-to-equity limit and the documentation rules all bite on the same payments. Employers of expatriates should read Personal income tax, PAYE and expatriates with Social security and RSSB contributions. Exit planning starts on entry: the 10% capital gains tax on direct and indirect share transfers is in Capital gains, property and other taxes, and importers should read Customs and EAC trade. Tax administration, audits and disputes explains what happens when RRA asks questions. Each section ends with the related Be Rwanda Wise FAQs, the official sources and a question you can put to Rwandabot, the AI legal-information chatbot, about your own facts. Figures are stated at 10 October 2026. Several dates fall within the next two years, among them the step in the pension contribution rate on 1 January 2027 and the end of the VAT exemptions for energy equipment and electric vehicles on 30 June 2028, and the digital services tax still awaits its Order, so check the position again before relying on it for a later transaction.
Sections in this chapter
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Official sources
- Rwanda Revenue Authority: Law N° 027/2022 of 20/10/2022 establishing taxes on income, Articles 4, 5, 9, 25, 27, 31, 33, 45, 48, 49 and 68
- Official Gazette n° Special of 14/09/2023: Law N° 051/2023 of 05/09/2023 amending Law N° 027/2022 (28% rate; Article 9)
- Official Gazette n° Special of 29/05/2025 (MINIJUST): Law N° 014/2025 of 27/05/2025 amending Law N° 027/2022
- Ministry of Finance and Economic Planning: Government of Rwanda integrates BDF into BRD (press release, 31 July 2025)
- Rwanda Revenue Authority: Ministerial Order N° 009/26/10/TC of 24/09/2026 (permanent residence, effective management, certification threshold)
- Rwanda Revenue Authority: Ministerial Order N° 003/26/10/TC of 29/04/2026 (transfer pricing, simplified accounting, losses)
- Rwanda Revenue Authority: Basic Information on Rwanda Taxation System (November 2025)
- Rwanda Revenue Authority: Law N° 049/2023 of 05/09/2023 establishing value added tax, Articles 3 to 31
- Rwanda Revenue Authority: Law N° 020/2023 of 31/03/2023 on tax procedures, Articles 11, 17, 18, 84 and 87 to 89
- Rwanda Revenue Authority: Ministerial Order N° 004/26/10/TC of 29/04/2026 (VAT on online supplies, invoice adjustment, industrial exemption)
- Rwanda Revenue Authority: Commissioner General Guidelines for the Implementation of the VAT Deferral Facility (in force 1 August 2026)
- Rwanda Revenue Authority: Ministerial Order N° 006/26/10/TC of 24/09/2026 on the electronic invoicing system, waiver of tax and award for reporting evasion
- Rwanda Revenue Authority: Ministerial Order N° 003/24/03/TC of 08/03/2024 (foreign services not available in Rwanda)
- Rwanda Revenue Authority: International Agreements (treaty texts and the Convention on Mutual Administrative Assistance)
- Capital Market Authority: Law N° 006/2021 of 05/02/2021 on Investment Promotion and Facilitation (Annex, withholding tax incentives)
- Rwanda Social Security Board: pension reform questions and answers (Presidential Order N° 086/01 of 12/12/2024)
- OECD: members of the Inclusive Framework on BEPS (updated 5 December 2025)
- Rwanda Revenue Authority: Law N° 048/2023 of 05/09/2023 determining the sources of revenue and property of decentralized entities
- Rwanda Revenue Authority: Ministerial Order N° 002/23/10/TC of 24/11/2023 on land tax rates per square metre
- Rwanda Revenue Authority: East African Community Customs Management Act, 2004 (compiled text)
- Rwanda Revenue Authority: EAC Gazette Vol. AT 1 No. 14 of 30 June 2022 (CET structure, stays and remissions)
- Rwanda Revenue Authority: Electronic Single Window processes and procedures
- East African Community: Ministers adopt 35% as the CET fourth band (6 May 2022)
- Rwanda Revenue Authority: Taxation Procedures guide (August 2023)
- Rwanda Revenue Authority: Ministerial Order N° 001/24/03/TC of 08/03/2024 on voluntary disclosure
- Rwanda Revenue Authority: laws, policies and rulings
The other chapters
This page gives legal and tax information, not legal advice. Rates, thresholds and procedures change; the content is reviewed against official sources, but you should confirm anything important with the relevant authority or an advocate registered with the Rwanda Bar Association before you act. Laws are published in Kinyarwanda, English and French in the Official Gazette; check the official text before relying on a translation.