Double Tax Treaties of Rwanda

At a glance

Key points for investors, businesses and people receiving income across borders.^1,2,3,4

Source: Rwanda Revenue Authority: International Agreements; Rwanda Revenue Authority: Tax Laws; Rwanda Revenue Authority: RRA Tax Handbook 2025; Ministry of Finance and Economic Planning: How Rwanda Will Benefit by Joining International Convention of Tax Matters^1,2,3,4

The published treaty partners

The RRA’s international agreements page lists 16 bilateral agreements. The partner names below follow that page; Belgium is shown with its amending protocol, and Jersey is listed separately. The list describes agreements published by the tax authority. It should not be read as a statement that every agreement has identical terms or applies to every payment.¹

Partners grouped by region for easier reference.¹

Source: Rwanda Revenue Authority: International Agreements¹

The RRA lists separate agreements for Belgium and Luxembourg, as well as an agreement and an amending protocol concerning Belgium. The United States Department of State’s 2024 Rwanda investment climate statement describes the arrangement as one with the Belgium-Luxembourg Economic Union. For checking the published treaty documents, use the RRA’s own country-by-country listing and read the relevant agreement rather than assuming that similarly named arrangements have the same scope.^1,5

A separate entry in Rwanda’s tax-law listing refers to a presidential order ratifying a convention with the Democratic Republic of Congo for the avoidance of double taxation. This is distinct from the Republic of Congo, which appears in the RRA’s international agreements list. The 2024 US Department of State statement also names the Democratic Republic of the Congo among Rwanda’s double taxation agreement partners. Keep the two Congo country names distinct when identifying a treaty partner.^2,5

How treaty relief works

A double taxation agreement is intended to address situations where the same income could be taxed in more than one country. In practice, the agreement relevant to a payment matters: the partner country, the type of income and the wording of that treaty all need to be considered together. The published list is a starting point for identifying a potentially relevant agreement, not a substitute for reading its terms.^1,5

The RRA’s 2025 tax handbook says withholding on service fees can be affected by double taxation agreements. It also states that a 15% withholding tax rate may be reduced under a treaty. For interest and dividends, the handbook gives treaty rates of 10% or 5%, depending on the agreement. Those figures are examples of treaty relief described by the handbook, not a single rate that applies to all treaty partners or income.³

When assessing a cross-border payment, work through these questions:^1,3

• Which country or territory is the other party resident in?
• What is the payment for? The RRA handbook specifically discusses service fees, interest and dividends.
• Does the RRA publish an agreement with that partner?
• What rate and conditions does the relevant agreement provide for that type of income?
• Is the rate being considered the domestic rate or a treaty rate?

Source: Rwanda Revenue Authority: International Agreements; Rwanda Revenue Authority: RRA Tax Handbook 2025^1,3

Withholding rates and what they mean

Withholding tax is deducted from a payment at source. A treaty may change the amount withheld where its terms allow a lower rate. The RRA handbook’s 2025 figures show why it is important to distinguish the general 15% rate mentioned there from the lower treaty rates it gives for interest and dividends. A payment’s description alone does not establish which treaty rate applies; the relevant agreement must be checked.³

Rates cited in the RRA’s 2025 handbook.³

Source: Rwanda Revenue Authority: RRA Tax Handbook 2025³

These rates are not a universal schedule for every treaty partner. The handbook describes possible reductions, while the RRA’s agreements page provides access to specific agreements and protocols. A resident, company or adviser comparing a proposed payment should therefore match the income category to the actual treaty text instead of applying the lowest figure in the handbook automatically.^1,3

A practical way to check an agreement

Start by identifying the relevant partner from the RRA’s international agreements list. Check the exact country or territory name: for example, the list includes both the Republic of Congo and Belgium, while the tax-law listing separately refers to a convention with the Democratic Republic of Congo. Country names that appear similar do not point to the same agreement.^1,2

Next, identify the payment category. The RRA handbook discusses service fees, interest and dividends, and gives lower treaty rates for interest and dividends in some agreements. Use the treaty text for the partner concerned to check what it says about that category and the relevant rate. A rate cited for one type of payment should not be carried across to another type.^1,3

Finally, distinguish a treaty’s existence from the rate that applies to a particular transaction. The RRA’s page includes agreements, a protocol and the multilateral convention in one international-agreements listing. These instruments do different jobs. For a tax calculation, focus on the bilateral agreement and any protocol relevant to the partner and payment; for information exchange and administrative cooperation, the multilateral convention is relevant.^1,4

Tax information exchange

Rwanda is party to the Convention on Mutual Administrative Assistance in Tax Matters, also referred to as MAAC. It is a multilateral instrument, rather than one of the bilateral agreements in the RRA’s list of partner-country treaties. The Ministry of Finance and Economic Planning describes it as a framework for cooperation between tax administrations and for exchanging information for tax purposes.^1,4

The convention covers more than information supplied on request. The Ministry’s explanation names exchange of information on request, automatic and spontaneous exchange, simultaneous tax examinations, examinations abroad, assistance in recovering tax claims and assistance with serving documents. It also describes the convention as supporting the enforcement of countries’ domestic tax laws and cooperation against international tax evasion and avoidance.⁴

For businesses and individuals with cross-border financial affairs, this is a separate part of the treaty landscape from a reduced withholding rate. A bilateral agreement may affect how income is taxed; the multilateral convention provides routes for tax administrations to cooperate and exchange information. Rwanda’s participation in both forms of agreement means that the relevant question depends on whether the issue is a payment’s tax treatment or administrative cooperation.^1,4

Before relying on a treaty

Use the RRA’s published international agreements page to locate the relevant agreement, and compare its wording with the payment being considered. The 2025 handbook gives a useful overview of domestic withholding and possible treaty reductions, but its 10% and 5% figures depend on the agreement. For a particular transaction, confirm the current text and application with the Rwanda Revenue Authority before using a reduced rate.^1,3