A Guide To Taxation in Rwanda: 2015 Tax Facts and Figures
A Guide To Taxation in Rwanda: 2015 Tax Facts and Figures
A Guide To Taxation in Rwanda: 2015 Tax Facts and Figures
com/rw
A guide to
taxation in
Rwanda
2015 tax facts and
figures
Table of contents
A guide to taxation in Rwanda 2015 tax facts and figures
Introduction 1
The PwC network
Africa
Our clients
PwC Rwanda
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Taxation of individuals
Monthly tax rates (individuals)
Income from employment
Contributions to retirement benefit schemes
Benefits in kind
Non-taxable benefits/income
Resident individuals
Non-resident individuals
Pay-as-you-earn tax (PAYE)
Tax year of assessment (individuals)
Calculating income tax payable
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9
9
9
10
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11
11
11
11
12
Corporate tax
Rates of tax
Small business taxpayers
Entities subject to corporate income tax (CIT)
Entities exempt from CIT
Tax period (companies)
Deductions allowed
Deductions not allowed
Tax depreciation allowances
Carryover of tax losses
Capital gains
Corporate reorganisation
Dividends
Rental income
Free-trade zone developers and foreign companies with headquarters
in Rwanda
Lease transactions
Law on minerals tax
Gaming law
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14
14
15
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16
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18
18
18
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20
PwC
International transactions
Geographical source of income
Double tax treaty (DTT)
Foreign tax credit
21
22
22
22
Anti-avoidance schemes
Transfer pricing
Thin capitalisation
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24
24
25
Exempt income
27
Administrative procedures
Tax declaration companies
Tax declaration individuals
Notice of assessment
Payment of tax
Persons allowed to sign the declaration
E-filing and e-payments
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30
30
30
30
31
31
Value-Added Tax
32
Scope of VAT
VAT rates
VAT reverse charge
Time of supply
Compliance obligations
Input tax not deductible (blocked VAT supplies)
Time limit for claiming input tax
Tax paid prior to registration
VAT refund
Withholding VAT
Electronic billing machines (EBMs)
Taxable value of goods or services
Requirements of a valid tax invoice
Simplified tax invoice
Exempt supplies
Offences and penalties
In duplum rule:
Forms of declaration
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35
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Introduction
PwC
Africa
In sub-Saharan Africa, were the largest
provider of professional services with
offices in 26 countries and close to 8000
people. This enables us to provide our
clients with a seamless and consistent
service, wherever theyre located on
the continent. Our in-depth knowledge
and understanding of African operating
environments enables us to put ourselves
in our clients shoes and offer truly
tailored tax, assurance and advisory
solutions to unique business challenges.
Our clients
We have a strong and diverse client base.
Our aim is to help create the value our
clients are looking for. Our global scale
and reach, combined with our specialist
knowledge in local and regional markets,
bring a rich diversity of skills, expertise
and experience to our clients. Our
clients include private sector businesses,
both multinational and national; civil
society organisations; and government
institutions.
Our clients benefit from access to
our peoples industry and technical
knowledge, and their ability to tailor
solutions to clients specific needs.
PwC Rwanda
PricewaterhouseCoopers Rwanda Limited
(PwC Rwanda) is a member firm of
PricewaterhouseCoopers International
Limited. All member firms are separate
legal entities. PwC Rwanda has access
to the global firms vast resource base of
proprietary knowledge, methodologies
and experience.
Our local capability comprises national
professionals and expatriate residents
who are able to combine their in-depth
understanding of local business, social,
cultural and economic issues with
their extensive functional and industry
knowledge. All our local experts are
able to draw from the combined skills,
experience and successes of other
specialists within the PwC network,
ensuring that our clients receive worldclass service.
Key contacts
Bernice Kimacia
bernice.w.kimacia@rw.pwc.com
Nelson Ogara
nelson.o.ogara@rw.pwc.com
Paul Frobisher Mugambwa
frobisher.mugambwa@rw.pwc.com
PwC
Resident persons
Taxable income
employment income
business profits
investment income.
PwC
Taxation of individuals
8
Taxable income
Rwf
Tax rate
Rwf
0 30000
30000
0%
30001 100000
70000
20%
100000 +
Contributions to retirement
benefit schemes
The Government has established a
national pension scheme, the Rwanda
Social Security Board (RSSB), to provide
social security services to employees in
Rwanda. The RSSB requires all salaried
workers in Rwanda, both nationals and
foreigners, to contribute to the scheme.
Rates of contribution
The employer must contribute 3% of the
employees gross salary to the pension
scheme. The employees contribution
is also 3%. The employer must also
contribute 2% of the employees gross
salary towards a mandatory occupational
hazards scheme.
30%
Remittance of contribution
The employer must deduct social security
contributions from employees every
month. Employers may remit the total
contribution once a quarter, in the month
following the end of each quarter.
An employer cannot recover the
employees contribution by deducting in
arrears.
The mandate for collecting social security
contributions was transferred to the
Rwanda Revenue Authority (RRA) in the
second quarter of 2010.
PwC
Benefits in kind
Benefits in kind (non-cash benefits) received from employment are generally taxable.
When the employer provides the following facilities to an employee, the benefit is taxed
as follows:
Facility provided
Taxable benefit
Motor vehicle
(with or without a driver)
Accommodation
(whether furnished or not)
Other benefits
Non-taxable benefits/income
Resident individuals
Non-resident individuals
PwC
11
Question
Calculate the income tax payable by a resident individual whose annual income is
Rwf45000000. The employee is provided with furnished accommodation and a
fuelled car for private use. The employee has two children attending school. The
employer provides an education allowance of Rwf 7,200,000 a year, paid on a
monthly basis.
Solution
Item
Salary
Education allowance
Total cash
2014
Monthly*
Rwf
3750000
600000
4350000
870000
435000
Taxable income*
PAYE thereon
Net pay
*The annual salary has been divided by 12 to give a monthly salary.
5655000
16805000
3974500
Corporate tax
PwC
13
Rates of tax
The income tax rates applicable to
companies are as follows.
Generally, businesses pay tax at the rate
of 30%.
Newly listed companies on capital markets
are taxed as follows for a period of five
years.
If the company sells at least 40%
of their shares to the public:
20%
If the company sells at least 30%
of their shares to the public:
25%
If the company sells at least 20 %
of their shares to the public:
28%
The following companies pay 0% tax:
Venture capital companies registered
with the Capital Markets Authority in
Rwanda
Investment entities that operate in a
Free Trade Zone
Foreign companies that have their
headquarters in Rwanda
Companies that carry out micro-financing
activities pay 0% for five years.
Registered investors are entitled to a
profit tax discount if they employ a certain
number of Rwandans, as detailed below,
for at least six months during a tax period.
2%
5%
6%
3%
5%
2000000 to 4000000
60000
4000001 to 7000000
120000
7000001 to 10000000
210000
10000001 to 12000000
300000
PwC
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Deductions allowed
Expenses may be deducted for tax
purposes if they:
were incurred for the direct purpose
and in the normal course of business;
can be substantiated with proper
documents;
lead to a decrease in the net assets of
the business; or
were used for activities relating to the
tax period in which they are incurred.
Non-business expenses;
Entertainment expenses;
Tax depreciation
Tax depreciation is granted to persons who own depreciable assets at the end of the tax
period and use those assets to produce income.
Type of asset
Rate
Not Applicable
Nil
Straight line
5%
Straight line
10%
Reducing-balance
50%
Reducing balance
25%
Investment allowance
Not Applicable
40%
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Type of asset
Rate
Investment allowance
N.A.
50%
Corporate reorganisation
Capital gains
Capital gains arising from the sale
or cession of commercial immovable
property are taxed at the rate of 30%.
However, capital gains arising on
secondary market transactions on listed
securities are exempt from tax.
Dividends
Dividends and similar distributions
received from an investment in Rwanda
by a resident or non-resident person are
subject to final withholding tax at 15%.
The withholding tax on dividends does
not apply to a dividend paid by a resident
company to another resident company.
Rental income
Income received from the rental of
machinery, land and livestock are
included in the taxable income, reduced
by:
10% of gross revenue as deemed
expenses;
interest paid on the loans; and
tax depreciation expense.
Income received from the rental of
buildings or houses is subject to corporate
income tax, and not taxed as set out
above.
Lease transactions
The law currently recognises both
operating and finance leases. Under an
operating lease arrangement, the lessor
qualifies for depreciation allowances
while paying tax on lease payments it
receives from the lessee. In the case of a
finance lease, the lessor is liable to tax on
the lease rentals and does not qualify for
capital allowance. Instead, the allowance
is allowed to the lessee.
PwC
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Gaming law
Tax on gaming activities is 13% of the
difference between the total amounts
wagered and the winnings awarded. The
tax return must be submitted and the tax
due paid to the RRA within 15 days of the
end of each month.
Gaming activity is defined as any
game played with cards, dice, tickets,
equipment, or any mechanical, electronic
or electromechanical device or machine,
for money, property, cheque, credit or
credit card or any other representative
value. A wager refers to a sum of money or
representative of the value that is risked
on an occurrence for which the outcome is
uncertain (a bet).
A withholding tax of 15% shall be
levied on the net winnings of a player of
gaming activities. The 15% tax applies
to the difference between the winnings
of a player and the amount wagered. In
calculating withholding tax, income of up
to Rwf30,000 shall be taxed at 0%.
The tax return must be submitted and the
tax due paid to the RRA within 15 days of
the end of each month.
International transactions
PwC
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Geographical source of
income
Income from sources in Rwanda includes:
Income generated from services
performed in Rwanda, including
income generated from employment.
Income from employment exercised in
Rwanda is treated as being derived or
accrued in Rwanda and is taxable in
Rwanda, whether paid in Rwanda or
elsewhere;
Income generated by a craftsperson,
musician or a player from his or her
performance in Rwanda;
Income generated from activities
carried out by a non-resident through a
permanent establishment in Rwanda;
Income generated from the sale
of immovable assets owned by a
permanent establishment in Rwanda;
Income generated from the following
assets in Rwanda:
immovable assets and accessories
thereto,
livestock and inventory generated
from agriculture and forestry,
rights derived from an immovable
asset, if such as asset is in Rwanda,
and
income generated from the sale of
the abovementioned assets;
Dividends distributed by a resident
company;
Anti-avoidance schemes
PwC
23
Transfer pricing
Thin capitalisation
25
A resident individual or resident entity must deduct withholding tax of 15% when
making the following payments:
Income
Rate (%)
15
Interest listed securities and listed bonds with maturity of three years
and above
Dividend
5
15
Royalty income
15
Service fees, including management and technical services fees, with the
exclusion of international transport
15
15
15
15
The withholding tax deducted should be paid to the RRA within 15 days of the month of
the deduction. Confirmation of this payment should be provided to the recipient of the
income.
The withholding tax on payments to countries for which Rwanda has a double tax treaty
is as follows:
Services
South Africa
Belgium
Mauritius
Dividends
10%
0%
10%
Interest
10%
10%
10%
10%
10%
12%
Royalties
10%
10%
10%
The application of the DTT rates is subject to the recipient of the payments meeting
certain conditions. Professional advice should be sought before applying the above rates.
Exempt income
PwC
27
Administrative procedures
PwC
29
Payment of tax
Notice of assessment
The Commissioner General may raise a
notice of assessment on a taxpayer in the
following instances:
PwC
31
Value-Added Tax
32 A guide to taxation in Rwanda 2015 tax facts and figures
Scope of VAT
VAT rates
PwC
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Compliance obligations
Time of supply
VAT on the supply of goods and service
must be accounted for with reference to
the tax point rules.
The tax point for any supply will be the
earliest of the:
date of supply
date of invoice
date of payment
date on which goods are either
removed from the premises of the
supplier or given to the recipient.
VAT refund
If a person registered for VAT is in a
position to claim a VAT refund because
of input tax exceeding output tax, the
Commissioner General may order the
claim to be verified, and the taxpayer and
RRA must respond within three months
of the date the claim was lodged. All
outstanding tax declarations should be
filed.
If a person registered for VAT is in a
position to claim a VAT refund because
of input tax exceeding output tax, the
Commissioner General may order the
claim to be verified. In the event of an
audit, the RRA must respond within
three months from the date the claim was
lodged. All taxpayers outstanding tax
declarations should have been filed.
Withholding VAT
As set out in the international agreements,
foreign diplomatic missions, foreign
governments and international
government organisations are eligible for
VAT refunds on goods and services. The
Commissioner General sets procedures for
claiming these refunds.
Government and public institutions
must withhold VAT on taxable supplies
when making payment to suppliers. The
VAT withheld is remitted to RRA by the
fifteenth day of the following month. The
supplier must account for output VAT and
show the VAT declared as a credit, thus
resulting in a nil effect.
PwC
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Penalty (Rwf)
5000 000
10000 000
above 400,000,000
20000 000
Administrative fines are also levied. These range between Rwf500000 to Rwf10 million,
depending on the taxpayers turnover.
Invoices that do not include this information may be admissible if they contain:
The selling price including VAT; or
A statement that the price includes VAT, with the rate of VAT provided.
Simplified tax invoice EBM receipt.
Exempt supplies
Supplies that are specifically exempt are as listed below:
Item
Description
PwC
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Item
Description
Precious metals
Item
Description
Any goods or services in connection with the burial or cremation of a body, as provided
by an order of the Minister in charge of finance.
Energy supply equipment appearing on the list made by the Minister in charge of energy
and approved by the Minister in charge of taxes.
Trade union subscriptions
Leasing of exempted goods
All agricultural and livestock products, except processed ones which are exempted from
value-added tax. However, processed milk (excluding milk and milk-derived products) is
exempted from this tax.
Agricultural input and other agricultural and livestock materials and equipment appearing
on the list made by the Minister in charge of agriculture and livestock, and approved by
the Minister in charge of taxes.
Personal effects of Rwandan diplomats returning from foreign postings, and Rwandan
refugees and returnees entitled to tax relief under customs laws.
Goods and services meant for special economic zones (SEZs) imported by a registered
SEZ operator.
Mobile telephones and subscriber identification module (SIM) cards;
Information communication and technology equipment appearing on the list made by
the Minister in charge of information and communication technology, and approved by
Minister in charge of taxes.
Description
PwC
39
Item
Description
41
There is a comprehensive and punitive system of fixed penalties and interest payable
for non-compliance with Rwandan tax laws. Offences include incorrect declarations on
returns, late submission of tax declarations or payments, and the understatement of tax
payments, among others. In some cases, criminal liability also applies.
Monetary penalties for various offences relating to corporate tax, PAYE, VAT and
withholding tax are shown in the table below.
Offence
Category of taxpayer
All taxpayers
Rwf100000
Rwf300000
Rwf500000
All taxpayers
Offence
Category of taxpayer
Understatement fines
All taxpayers
Administrative penalties
All taxpayers
A taxpayer who has declared
due taxes on time but did not
pay the taxes on time:
All taxpayers
Operation without VAT
registration where VAT
registration is required:
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Offence
Category of taxpayer
Tax fraud
All taxpayers
In duplum rule:
Interest accrued cannot exceed 100% of the amount of tax.
The late-payment fine does not apply to interest or administrative fines.
Notes
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The information contained in this tax guide is provided for general information
purposes only, and does not constitute the provision of legal advice in
any way. Before making any decision or taking any action, a professional
adviser should be consulted. No responsibility for loss to any person acting
or refraining from action as a result of any material in this tax guide can be
accepted by the author, copyright owner or publishers.
2015 PricewaterhouseCoopers Rwanda Limited. All rights reserved.
PricewaterhouseCoopers refers to the network of member firms of
PricewaterhouseCoopers International Limited, each of which is a separate
and independent legal entity. (15-16811)