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Category: Insights

Insights

Double Tax treaty Rwanda – Luxembourg

The Republic of Rwanda and the Grand Duchy of Luxembourg struck an agreement in 2021 that eliminates the double taxation on economic actors. This allows businesses and investors wishing to invest in both nations to do so without having to pay cumulated taxes. The double tax avoidance agreement (DTAA) serves as an incentive for companies […]

Insights

Kigali International Finance Center (KIFC) & Why Rwanda remains the best kept secret for Capital Markets?

Rwanda, which has one of the continent’s fastest-growing economies, is in the forefront of pan-African integration by creating and facilitating an environment for investments in Africa. The country aspires to become a pan-African financial hub that facilitates cross-border investments throughout Western, Eastern, and Central Africa. Rwanda Finance Limited (RFL) is a private company mandated to […]

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Adelit Nsabimana, Phd

Tax and Legal Lead

Over the last 19 years, Adelit Nsabimana has developed a professional experience in various economic development and financial sectors. For the last eight years, he worked as the Economic advisor to the Minister of Finance and Economic Planning and the technical advisor to develop the Kigali International Financial Centre (KIFC) under Rwanda Finance which is an agency of the Government of Rwanda mandated to promote and develop KIFC. Before being involved in public policy and strategy engagements and as a medium level professional staff, he gained an experience of over 11 years in public finances and the banking industry. He was the responsible of the Internal Audit department in Bancor (the current Access Bank Rwanda) for two years after working as an auditor and a team leader in the Office of the Auditor General of State Finances in the Government of Rwanda for five years, as a Credit Analyst in COGEBANK and “Union des Banques Populaires” du Rwanda for four years. Academically, he holds a PhD degree in Economics from Nelson Mandela University in South Africa and a master’s degree in economics from the University of KWAZULU Natal, South Africa.

Intellectual Property Company

Defined as: a commercial entity that is established for the sole purpose of owning intellectual property rights.

Governing Law

Law N° 006/2021 of 05/02/2021

Tax incentives

  • 3% preferential corporate income tax rate on foreign sourced royalties.
  • 0% preferential withholding tax on dividends, interest and royalty payments

Substance requirements

  • Annual expenditure in Rwanda of at least USD 10.000;
  • A physical office in Rwanda;
  • To have a bank account in a bank operating in Rwanda;
  • At least thirty per cent (30%) or three (3) of the staff are Rwandan residents, whichever is higher;
  • At least twenty five per cent (25%) or one (1) of the directors reside in Rwanda.

Double Taxation Treaties

In addition to multinational tax treaties such as the East African Community Double Taxation Agreement, Rwanda has signed 17 bilateral double taxation agreements (DTAs) and others are under negotiation. Rwanda has DTAs with Angola, Belgium, Czech Republic, Democratic Republic of Congo, France, Jersey, Korea, Mauritius, Singapore, Turkey, United Arab Emirates, China, Luxembourg, Barbados, Morocco, Qatar and South Africa.

Partnerships

Governing Law: Law N° 008201 0f 16/02/2021

  • General Partnerships / Limited Partnership / Limited Liability Partnership / Foreign Partnership
  • May be formed for a fixed term or for an indeterminate duration
  • Income generated from a general partnership, limited partnership and limited liability partnership is taxable at the level of each partner
  • The partnership prepares its financial accounts, determines, and declares the taxable share in profit of each partner, withholds, and remits corresponding tax to the tax administration
  • In the determination of tax liability, corporate partners are subject to corporate income tax while individual partners are subject to personal income tax
  • The partnership and the partners are jointly liable in the case of a failure to meet their tax obligations

Trusts

Governing Law: Law N° 063/2021 of 14/10/2021

  • Charitable Trust / Protective Trust / Purpose Trust / Ordinary Trust
  • Either established in Rwanda or in a foreign country with Rwanda Law as Governing law
  • All Trust instruments must be registered by the Registar General
  • 30% Corporate Income Tax, payable annually
  • Exemption applied to a resident trustee for income earned by a foreign Trust

Jean-Marie Ningenzi

Compliance Director

Jean-Marie Ningenzi has over 13 years of experience in the financial services industry. He held day-to-day responsibility for the compliance activities of Clients at an international fund and corporate service provider in Luxembourg. During his tenure, he managed an array of clients and investors located in various segments and locations. Jean-Marie is a member of the Association of Certified Anti-Money Laundering Specialists (ACAMS).

Christian Mutoni

Finance Director

Christian has over 10 years of experience in finance related  functions. He started his career as financial auditor for one of the Big Four accounting firms in Luxembourg, followed by a couple years in operational and internal audit for a prominent multinational agro-food company.

Lately, he was part of the Finance and Treasury department of a French listed company, working on cash optimization and financing solutions.

He holds a Master’s degree in Finance from the Louvain School of Management (Belgium)

Eric Bwanakeye

Funds Director

Eric has more than 15 years of experience in the fund industry. He has led teams in charge of NAV oversight and structured Alternative Investment Funds in a fund management company. He has extensive experience in client relationship management and business development. He also served as independent director for several Alternative Investment Funds.

Jean-Patrick Muhire

Managing Director

Jean-Patrick is an experienced finance professional with a demonstrated history of working in the financial services industry. He has extensive experience in the establishment and management of international corporate and private structures for both corporations and high-net-worth individuals. He has over 15 years professional experience in Financial Accounting, Tax Compliance, and Corporate Governance and has worked with many well-known UK and US Private Equity firms. His career has allowed him to spend time working in several locations, including Rwanda, Belgium, UK, the US and Luxembourg.

A registered investor licensed to operate as either of the following:

•fund management entity •collective investment scheme •wealth management service provider •financial advisory commercial entity •family office services entity •fund administrator •financial technology commercial entity •captive insurance scheme entity •private bank •mortgage finance institution •finance lease commercial entity •asset backed securities entity •reinsurance company •trust and corporate service provider

Economic Substance Required

• No economic substance requirements, provided it is covered through the license requirement under the relevant specific regulations

Tax Incentive

• 15% Preferential corporate income tax rate
• 0% Preferential withholding tax on dividends, interest, and royalty payments

Foundations

Governing Law: Law N° 059/2021 of 14/10/2021

  • Private-Benefit / Mixed-Benefit / Common-Benefit
  • Either established in Rwanda or in a foreign country and apply for registration in Rwanda as a legal entity separate from its founder
  • 30% Corporate Income Tax, payable annually
  • Exemption applied to Common-Benefit Foundations

Global Trading or Paper Trading

Defined as: a commercial entity making deposits in financial entities in Rwanda to finance its trading activities outside Rwanda and not authorised to import or export goods in Rwanda.

Governing Law

Law N° 006/2021 of 05/02/2021

Tax incentives

  • 3% preferential corporate income tax rate on foreign sourced trading income.
  • 0% preferential withholding tax on dividends, interest and royalty payments

Substance requirements

  • An annual turnover or trade volume of not less than USD 10,000,000;
  • An annual expenditure in Rwanda of at least USD 50,000;
  • At least thirty percent (30%) of the professional staff are Rwandan;
  • A physical office of the company in Rwanda;
  • At least twenty five percent (25%) of the directors reside in Rwanda.

Collective Investment Scheme

Defined as: a type of scheme where there is an arrangement for collecting and pooling funds from investors or participants for the purpose of investment in the interest of each participant or investor represented by his or her proportional ownership in the pool.

Governing Law

Law N° 062/2021 of 14/10/2021

Tax incentives

  • 3% preferential corporate income tax rate.
  • 0% preferential withholding tax on dividends, interest and royalty payments

Substance requirements

  • Minimum fund size not less than USD 1,000,000 within the first three (3) years;
  • Minimum expenditure in Rwanda of USD 50,000 per year;
  • Collective Investment Scheme manager, custodian and operator established in Rwanda;
  • At least thirty percent (30%) of the professional staff are Rwandan;
  • At least twenty five percent (25%) of the directors reside in Rwanda.

Special Purpose Vehicle registered for investment purpose

Governing Law

Law N° 006/2021 of 05/02/2021

Tax incentives

  • 3% preferential corporate income tax rate.
  • 0% preferential withholding tax on dividends, interest and royalty payments

Substance requirements

  • Registered for investment purpose in projects, which are meant to last for more than two (2) years;
  • Total net assets consolidated in Rwanda not less than USD 1,000,000;
  • Annual expenditure in Rwanda of at least USD 15,000;
  • A physical office of the company in Rwanda;
  • At least thirty percent (30%) of the professional staff are Rwandan;
  • At least twenty five percent (25%) of the directors reside in Rwanda.

Pure Holding Company

Governing Law

Law N° 006/2021 of 05/02/2021

Tax incentives

  • 3% preferential corporate income tax rate.
  • 0% preferential withholding tax on dividends, interest and royalty payments

Substance requirements

  • Total net assets consolidated in Rwanda not less than USD 1,000,000;
  • Annual expenditure in Rwanda of at least USD 15,000;
  • A physical office of the company in Rwanda;
  • At least thirty percent (30%) of the professional staff are Rwandan;
  • At least twenty five percent (25%) of the directors reside in Rwanda.