Mining 2026

RWANDA Trends and Developments Contributed by: Aimery de Schoutheete and Penina Ngabire, Liedekerke Great Lakes

Key Regulatory and Tax Reforms in Rwanda’s Mining Sector Introduction The Rwandan mining sector has seen significant legal and fiscal reforms in recent years, aimed at strength - ening regulation, formalising operations, and pro - moting sustainable development. Key developments include the 2024 Mining Law, the 2024 Minerals Tax Law, and the 2025 amendments to the income tax framework. These changes have reshaped licensing, taxation, and compliance requirements, influencing both operational and strategic considerations within the sector. This update highlights the main reforms and their implications for sector participants. The 2024 Mining Law The cornerstone of these reforms is the 2024 Min - ing Law (Law No 072/2024 of 26 June 2024), which repeals the previous 2018 mining legislation and came into force on 24 July 2024. This law reaffirms the valid - ity of all licences issued under the former regime until their expiry but introduces a stronger regulatory and enforcement framework. Notably, the law establishes harsher penalties for illegal mining and illicit mineral trading or export, including criminal sanctions, fines, and obligations for environmental rehabilitation. It also provides the government with increased discre - tion over strategic minerals, including the potential to acquire a stake in mining projects, thereby affecting investor rights and licensing considerations. The law emphasises professionalisation, formalisation of arti - sanal miners, and adherence to environmental and social governance standards, reflecting a broader commitment to sustainable and community-focused mining operations. The 2024 Minerals Tax Law Complementing the regulatory framework, the 2024 Minerals Tax Law (Law No 056/2024 of 26 June 2024) introduced a comprehensive tax regime for mineral extraction and trading. The law imposes royalties on mineral production, sets an export tax on raw miner - als, and establishes withholding obligations for local

processors or exporters. Royalty rates vary depending on mineral category, generally ranging between 0.5% and 3%, and the law implicitly incentivises value- addition through differential treatment of processed versus unprocessed minerals. The Minerals Tax Law strengthens compliance obligations and encourages the formalisation of operations, reflecting the govern - ment’s dual objective of expanding the sector’s con - tribution to national revenue while promoting respon - sible mining practices. The 2025 amendment to the income tax law Further reinforcing the fiscal environment, the 2025 amendment to the income tax law (Law No 014/2025 of 27 May 2025, amending Law No 027/2022) intro - duced significant changes relevant to mining inves - tors and companies. The amendment increased the capital gains tax rate from 5% to 10% and expanded its scope to include transfers of not only shares but also other securities, including mining licences, debt instruments, and other structured financial assets. These changes have direct implications for transac - tions involving the transfer of mining licences or equity interests in mining companies, affecting exit strate - gies and investment structuring. Collectively, the 2025 income tax amendment, alongside the 2024 Mining Law and Minerals Tax Law, reflects Rwanda’s efforts to modernise its fiscal and regulatory regime, provid - ing both clarity and new compliance obligations for sector participants. Conclusion Collectively, the 2025 income tax amendment, togeth - er with the 2024 Mining Law and Minerals Tax Law, modernise Rwanda’s mining fiscal and regulatory framework. For sector participants, these reforms introduce new operational and fiscal considerations, affecting licensing, royalty obligations, tax treatment of assets, and approaches to mineral export and processing. The changes contribute to a more for - malised and transparent mining sector, with clearly defined legal and fiscal responsibilities for operators and stakeholders.

330 CHAMBERS.COM