Mining 2025

RWANDA Law and Practice Contributed by: Aimery de Schoutheete and Penina Ngabire, Liedekerke Great Lakes

Corporate Income Tax A corporate income tax (CIT) is levied on the income generated by any mining company established in Rwanda. The tax rate was recently reduced from 30% to 28%. A taxpayer willing to carry forward losses must apply to the competent authority, the Rwanda Revenue Authority (RRA). As a rule, losses can - not be carried forward for more than five years. Value Added Tax VAT applies on goods and services at the stand - ard rate of 18%. However, some goods and services are zero-rated or exempt from VAT. For instance, exported minerals and minerals sold on the domestic market are zero-rated. Withholding Taxes There is a 15% withholding tax on dividends, interest, royalties, and service/management fees paid by a Rwandan entity to a foreign entity. The same applies to profits repatriated from Rwanda. There is also a 5% withholding tax on goods imported for commercial use. Capital Gains Tax A capital gains tax (CGT) of 5% is applicable on the direct or indirect sale or transfer of shares that are not listed on the capital market. Tax on Minerals (Mining Royalties) Rwanda has recently adopted Law No 056/2024 of 26 June 2024 establishing tax on minerals (the “2024 Minerals Tax Law”), which repealed Law No 55/2013 of 22 August 2013 on minerals tax. The 2024 Minerals Tax Law reduced tax rates on the sale of different categories of minerals nota - bly from 4% to 3% (for the category of all base metals), and from 6% to 0.5% (for the gold cat - egory). The Law also introduced new categories

of taxes on previously unclassified minerals, and a tax on minerals exported in raw form among

other changes. Licence Fees

Fees apply when an investor applies for, main - tains, renews or transfers an ML or a QL. When it comes to MLs, depending on the type of licence (exploration, mining, processing or trade licence) and on the size of the licensed area: • application fees can vary between RWF100,000 and RWF4.5 million; • annual fees can vary between RWF100,000 and RWF5 million; • renewal fees can vary between RWF100,000 and RWF9 million; and • transfer fees can vary between RWF900,000 and RWF4.5 million. As of the date of this article, RWF1,000 is equiv - alent to USD0.74. Annual Surface Rent The holder of a mining licence (granting its hold - er the right to mine the licensed area, and to process and sell the minerals extracted from the licensed area) must pay an annual surface rent of RWF6,500 per hectare (USD5.5/ha). Customs Duties As a member of the East African Community (EAC), Rwanda relies on the East African Com - munity Customs Management (Amendment) Act (EACCMA) and the East African Community Common External Tariff (EACCET) for levying custom duties. Under the EACCET, the following common external tariffs apply to goods originat - ing from outside the EAC: • 0% (raw materials);

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