# Rwanda Corporate Income Tax

Tax year 2026. The 28% rate dates from Law 051/2023, not from 2025 as our earlier file said.

## Who this applies to

Companies, cooperatives, state-owned companies, foundations, protected cells, entities of Districts or Kigali with income-generating activity, profit-seeking associations, and non-residents with a permanent establishment (art 44). A resident is taxed on business profit from all sources; a permanent establishment on the same basis through its Rwandan presence (art 47). Effective management in Rwanda is met by any one of: day-to-day control here, shareholder meetings here, books kept here, or main shareholders or directors resident here (Order 009 art 2).

## Rates, bands and thresholds

| Item | Amount | Tax year | Official URL |
|---|---|---|---|
| Corporate income tax | 28%, profit rounded down to FRW 1,000 (art 48) | 2026 | https://www.rra.gov.rw/fileadmin/user_upload/Law_amending_Income_Tax_Ok.pdf |
| Newly listed, 40% of shares to the public | 20% for 5 years | 2026 | same |
| Newly listed, 30% of shares to the public | 25% for 5 years | 2026 | same |
| Micro-enterprise and small business | Flat amounts and 3% as for individuals (art 49) | 2026 | https://www.rra.gov.rw/fileadmin/user_upload/Income_Tax_law_of_2022.pdf |
| Gaming company, not the national lottery | 40% of stakes less winnings; exempt from CIT (arts 45, 50) | 2026 | https://www.minijust.gov.rw/index.php?eID=dumpFile&f=130496&t=f&token=4b9d4de9658212b7aaeeb5c8a42c823a7b879d7b |
| Gaming winnings withholding | 25% (art 61) | 2026 | same |
| Digital services, substantial national presence | 1.5% of Rwanda-source gross revenue; needs an Order of the Minister (art 50 bis) | 2026 | same |
| Capital gains | 10% (art 36) | 2026 | same |
| Withholding, general | 15%: dividends, interest, royalties, service fees, performance fees, goods sold in Rwanda (see art 60), repatriated profit, reinsurance premiums | 2026 | https://www.rra.gov.rw/fileadmin/user_upload/Income_Tax_law_of_2022.pdf |
| Withholding, listed securities and bonds | 5% (residents or EAC beneficiaries; treasury bonds of 3 years or more) (art 60) | 2026 | same |
| Imports for commercial use | 5% of CIF, credited (art 62) | 2026 | same |
| Public tenders | 3%; 15% if unregistered or no prior declaration (art 63) | 2026 | same |
| Deposit-taking microfinance | 0% for 5 years, renewable once on conditions (Order 008) | 2026 | https://www.rra.gov.rw/fileadmin/user_upload/Ministerial_order___Financial_institutions.pdf |
| Certification | Turnover of FRW 1,000,000,000 or more; listed distributors and agents are out unless income earned exceeds it (Order 009 art 3) | 2026 | https://www.rra.gov.rw/fileadmin/user_upload/Ministerial_orders-Financial_statements.pdf |
| Transfer pricing file waiver | Turnover under FRW 600,000,000 and controlled transactions below FRW 10,000,000 or aggregate below FRW 100,000,000 (Order 003 art 19) | 2026 | https://www.rra.gov.rw/fileadmin/Folder_for_2025/Ministerial_Order_on_Simplified_Accounting_Method_April_2026.pdf |

## The base

Accounting profit under GAAP adjusted by the income tax law (arts 19, 49). Excluded: dividends between resident companies and unrealised exchange gains on outstanding loans (art 47). Non-deductible items, depreciation and loss rules: as in [rwanda-income-tax](rwanda-income-tax.md). Also non-deductible: management, technical and royalty fees to non-resident related persons above 2% of turnover, and related-party interest and realised exchange loss on loans above 4 times paid-up equity; the 4x rule does not apply to banks and insurers (art 25). A change of more than 25% in ownership of an unlisted company ends loss carry-forward (art 31). Bad debts need write-off, prior income inclusion and a court insolvency decision, or 3 years of steps for an individual debt under FRW 3,000,000 (art 30).

Exempt persons (art 45 as replaced): government, City of Kigali, districts, BNR, qualifying non-profits, qualified pension funds, RSSB, BRD, Agaciro, BDF, common-benefit foundations, resident trustees on foreign trust income, gaming companies. They still file statements by 31 March.

Restructuring is tax neutral for the transferor, with book values carried over (art 54). Partnerships are taxed at partner level (art 52). Liquidation surplus is a dividend (art 55). Withholding exemptions: exempt profits, tax clearance certificate, newly registered in the period (art 65).

Transfer pricing: related persons need a policy, local file and master file (Order 003 art 17); advance pricing agreements are available (arts 25-31; Law art 32). Failure to give information on controlled transactions costs 5% of their value (Law 020/2023 art 86).

Expenses without EBM receipt, customs or WHT support are recorded daily in E-Tax (Handbook).

## Deadlines and filing

| Item | Deadline |
|---|---|
| Annual declaration and balance | 31 March 2027 for 2026, or 3 months after an approved year-end |
| Prepayments | 30 June, 30 September, 31 December; or months 6, 9, 12 of an approved period |
| Withholding | 15 days after the month (art 64); declared in E-Tax (https://www.rra.gov.rw/en/domestic-tax-services/withholding-tax-wht/declare-withholding-tax) |
| Gaming tax | 15 days after each month |
| Exempt entity statements | 31 March |

### How to file

1. Log in at https://etax.rra.gov.rw.
2. Annexure Downloads, choose the CIT annexure; enable content, complete, validate, save.
3. Prepare Profit and Loss Account, Balance Sheet and Company Representative. At the threshold, the approved certifying firm uploads the Certified Financial Statements.
4. File any request first under online requests, CIT/PIT requests: extension for reports, exemption from certification, or disclaiming an incentive.
5. Enter prepayments and withholdings, tick the certifying box, submit.
6. Pay against the RRA Reference Number on the acknowledgement receipt.

Steps from https://www.rra.gov.rw/fileadmin/Folder_for_2025/RRA_Tax_Handbook_2025_Final.pdf, which predates Order 009. To change the tax period, ask the Minister in writing (art 8).

## Penalties and interest

| Fault | Consequence | Source |
|---|---|---|
| Late declaration, fixed fine (Law 020/2023 art 81) | FRW 50,000 for a non-commercial person or turnover over FRW 2,000,000 up to FRW 20,000,000; FRW 300,000 for a public institution or non-profit with turnover over FRW 20,000,000; FRW 500,000 for a notified large taxpayer | https://www.rra.gov.rw/fileadmin/user_upload/OG_n___Special_ter_of_31.03.2023_Uburyo_bw_isoresha_Tax_procedures_01.pdf |
| Repeat fault within 2 years | Fine doubled; third time, four times | same |
| Certified statements not filed when required | FRW 500,000 every month until filed | same |
| Late declaration and payment (art 82) | 20% of tax up to 30 days, 40% from day 31 to 60, 60% after 60 days | same |
| Declared on time, paid late (art 82) | 5% up to 30 days, 10% from day 31 to 60, 30% after 60 days | same |
| Understatement of 10% to 20% (art 83) | 10% of the understatement; doubles above 20%; none if corrected and paid before notice of audit, but art 82 fines apply | same |
| Late-payment interest (art 80) | 0.5% a month up to 6 months, 1% from 6 to 12 months, 1.5% after 12 months; not compounded; every started month counts; capped at 100% of the tax | same |
| Tax evasion (art 81) | Fine equal to the evaded tax, plus criminal penalties | same |

Payments offset principal tax first, then the fine, then interest (art 80). The Law's art 82 text reads "twenty percent (10%)" for the middle band; we follow the figure 10%, as the numeric text and the 5/10/30 scale show.

Failure to withhold makes the payer personally liable for the tax, fines and interest (art 66).

## Cross-border points

Service fees, interest, royalties and dividends to non-residents take 15% unless a treaty reduces it. A place of services counts as a permanent establishment after more than 90 days in 12 months (art 5). Reduced rates must be taken from the treaty text. Controlled transactions must be at arm's length.

## Two worked examples that recompute

**Example 1. Prepayment.** Last year tax FRW 28,000,000 on turnover FRW 1,000,000,000; this quarter turnover FRW 300,000,000; FRW 1,000,000 withheld.

```oa-check
name: Quarterly prepayment
inputs:
  prior_tax: 28000000
  prior_turnover: 1000000000
  quarter_turnover: 300000000
  withheld: 1000000
steps:
  - prepayment: prior_tax / prior_turnover * quarter_turnover - withheld
expected:
  prepayment: 7400000.00
```

**Example 2. Decision: how much management fee to charge from a foreign parent.** Turnover FRW 500,000,000. A fee of FRW 15,000,000 exceeds the 2% cap of 10,000,000. The FRW 5,000,000 excess costs FRW 1,400,000 of CIT at 28%. Charging 10,000,000 or less avoids that.

```oa-check
name: Related-party fee cap
inputs:
  turnover: 500000000
  fee: 15000000
steps:
  - cap: turnover * 0.02
  - excess: max(fee - cap, 0)
  - extra_tax: excess * 0.28
expected:
  extra_tax: 1400000.00
```

## Ask the client first

1. Entity type, residence, tax period?
2. Turnover against FRW 1 billion and FRW 600 million?
3. Related-party transactions, and their values?
4. Payments abroad? To which country?
5. Investment certificate or other incentive?
6. Gaming, listing or microfinance status?

## Sources

| Source | URL | Read on |
|---|---|---|
| Law 027/2022 establishing taxes on income (read: arts 3-5, 8-10, 12-21, 24-33, 36-38, 44-50, 56-69) | https://www.rra.gov.rw/fileadmin/user_upload/Income_Tax_law_of_2022.pdf | 2026-11-01 |
| Law 051/2023 amending the income tax law (whole) | https://www.rra.gov.rw/fileadmin/user_upload/Law_amending_Income_Tax_Ok.pdf | 2026-11-01 |
| Official Gazette Special of 29/05/2025: Law 009/2025 (VAT), Law 014/2025 (income tax) (whole of both) | https://www.minijust.gov.rw/index.php?eID=dumpFile&f=130496&t=f&token=4b9d4de9658212b7aaeeb5c8a42c823a7b879d7b | 2026-11-01 |
| Law 020/2023 on tax procedures (read: arts 15, 35, 78, 80-88) | https://www.rra.gov.rw/fileadmin/user_upload/OG_n___Special_ter_of_31.03.2023_Uburyo_bw_isoresha_Tax_procedures_01.pdf | 2026-11-01 |
| Ministerial Order 003/26/10/TC of 29/04/2026 (read: arts 17, 19, 32-33) | https://www.rra.gov.rw/fileadmin/Folder_for_2025/Ministerial_Order_on_Simplified_Accounting_Method_April_2026.pdf | 2026-11-01 |
| Ministerial Order 008/26/10/TC of 24/09/2026 (whole) | https://www.rra.gov.rw/fileadmin/user_upload/Ministerial_order___Financial_institutions.pdf | 2026-11-01 |
| Ministerial Order 009/26/10/TC of 24/09/2026 (whole) | https://www.rra.gov.rw/fileadmin/user_upload/Ministerial_orders-Financial_statements.pdf | 2026-11-01 |
| RRA, Declare withholding tax page (whole page) | https://www.rra.gov.rw/en/domestic-tax-services/withholding-tax-wht/declare-withholding-tax | 2026-11-01 |
| RRA Tax Handbook 2025 (read: E-Tax steps, real regime, PAYE, VAT declaration chapters) | https://www.rra.gov.rw/fileadmin/Folder_for_2025/RRA_Tax_Handbook_2025_Final.pdf | 2026-11-01 |

Not yet confirmed: whether the Order under art 50 bis has been issued (none on the RRA laws page as read 2026-11-01), so the 1.5% digital tax is not treated as live; the list of treaties and their rates, including the Hong Kong agreement the first draft cited, which no saved source shows; incentive rates under the investment law (Law art 69 points to it, not read); the Handbook line that goods sold in Rwanda fall within 15% was not tested; art 60 items 3 (royalties) was missing in our text extract and rests on the old file.