Be Rwanda WiseDoing Business in Rwanda

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.

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At a glance

Governing law

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

Pick the subject you need next. Each section goes into the detail, with the law, the numbers, the steps and the traps, and links you on to the next one.

3.1Corporate income taxWho pays Rwandan corporate income tax and at what rate, when a foreign company becomes resident or has a permanent establishment, what can and cannot be deducted, how losses and prepayments work, and what must be filed by 31 March.Read →3.2VAT and electronic invoicingWhen a business in Rwanda must register for VAT, what it charges and recovers, which exemptions survived the 2025 reform, how imported and online services are taxed, how refunds work, and what the September 2026 electronic invoicing Order requires.Read →3.3Withholding taxes and tax treatiesWhat a Rwandan payer must withhold on payments to non-residents and others, the reduced rates and exemptions, how and when to declare, and how Rwanda's tax treaties reduce the tax, with the rates in the treaty texts RRA publishes.Read →3.4Personal income tax, PAYE and expatriatesWhen an individual becomes tax resident in Rwanda, how employment income and benefits are taxed through PAYE, what employers file and when, how expatriates, short-term visitors and diplomats are treated, and the payroll contributions that sit alongside the tax.Read →3.5Transfer pricing and international taxHow Rwanda tests prices between group companies, what documentation must exist and when, how advance pricing agreements work, which interest and fees stop being deductible, and when a foreign company becomes resident or creates a permanent establishment.Read →3.6Capital gains, property and other taxesThe taxes beyond income tax and VAT that an investor meets on entry, ownership and exit: capital gains on shares and other assets, the digital services tax, the District taxes on property, rent and trading licences, excise duty, gaming tax and the 2025 levies.Read →3.7Customs and EAC tradeHow goods enter Rwanda: the East African Community customs law and tariff, how customs value is set, every tax collected at the border, how registered investors and zone users obtain exemptions, how regional trade preferences work, and how to challenge a customs decision.Read →3.8Tax administration, audits and disputesHow the Rwanda Revenue Authority registers, audits and assesses taxpayers, how an assessment is challenged from the draft rectification note to the Commercial Court, and what interest, fines and recovery powers apply.Read →

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Investor FAQs on this subject

Official sources

The other chapters

01Investment Framework & Market AccessThe 2021 Investment Code, sectors open to foreign investors and sector licensing, the forms an investment can take, RDB registration and the investment certificate, the Annex incentives, the Kigali International Financial Centre, special economic zones, and the guarantees, treaties and reporting duties that protect and bind investors.Open →02Company Set-up, Governance & ContractsChoosing a vehicle, registering online with the Rwanda Development Board, shares and shareholder rights, directors and the company secretary, beneficial ownership, branches of foreign companies, the yearly compliance calendar and the law of commercial contracts.Open →04Employment, HR & ImmigrationEmployment contracts and probation, the 40-hour week, leave and public holidays, pay and payroll deductions, RSSB pension and other contributions, work and residence permits, visas, termination and terminal benefits, and workplace rules, unions and labour disputes.Open →05Land & Real EstateLand tenure under the Land Law 2021, what foreign investors can hold, registration and title checks, property tax and transfer costs, building permits and the Kigali master plan, leases, expropriation, mortgages and the real estate business.Open →06Banking, Foreign Exchange & RepatriationRwanda's central bank, banks and other financial regulators, the foreign exchange rules and the Rwandan-franc rule with its 2025 fines, opening corporate bank accounts, offshore and foreign-currency borrowing, repatriating profits and capital, payments and mobile money, anti-money-laundering and sanctions duties, and capital markets, project finance and KIFC funds.Open →07Intellectual Property, Data & TechnologyTrade marks, patents, designs and copyright under the 2024 IP law, enforcement and anti-counterfeiting, licensing and technology transfer, personal data protection, cybersecurity, e-commerce, fintech and AI.Open →08M&A, Competition & ExitBuying a Rwandan company, due diligence, deal documents and the 10% capital gains tax, merger control under the 2026 competition law and the COMESA and EAC regimes, listed companies and takeovers, joint ventures and exit rights, solvent liquidation and deregistration, and insolvency.Open →09Arbitration & DisputesThe Rwandan courts and the Commercial Court in Kigali, commercial litigation step by step, arbitration under Law N° 005/2008 and at KIAC, enforcing foreign awards and judgments, court mediation and Abunzi, investor-State protection, and tax, procurement and regulatory appeals.Open →10Minerals, Mining, Oil & GasThe 2024 Mining Law and the Rwanda Mines, Petroleum and Gas Board, exploration, mining, trading, processing and quarry licences, the 2024 tax on minerals, 3T and gold traceability, mining agreements and community duties, strategic minerals and the 2025 regional deals, petroleum and Lake Kivu methane, and sanctions due diligence.Open →11AgricultureThe 2026 agriculture and animal husbandry laws and the regulators, farmland leases, marshlands, irrigation and water permits, agribusiness incentives, VAT, finance and insurance, seeds, fertilisers, pesticides and plant health, horticulture exports of fruit, vegetables and flowers, coffee, tea and other export crops, livestock, dairy, poultry and aquaculture, and agro-processing, food safety and contract farming.Open →

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.