Transfer Pricing in Rwanda
At a glance
The main points for businesses with Rwanda-related controlled transactions.1,2
| Topic | Practical position |
|---|---|
| Governing instrument | Ministerial Order N° 003/26/10/TC of 29 April 2026. |
| Core standard | Covered transactions must comply with the arm’s length principle. |
| Methods | The Order names five methods for determining arm’s length prices. |
| Documentation | EY reported that eTax accepts transfer pricing documentation as an annex to the annual corporate income tax declaration. |
| Request deadline | The earlier process required documentation within seven days of a written RRA request. |
Source: Official Gazette of the Republic of Rwanda: Ministerial Order No. 003/26/10/TC on transfer pricing and simplified accounting (April 2026); EY: Rwanda introduces transfer pricing documentation filing via eTax (April 2026)1,2
The Order covers transfer pricing as well as simplified accounting and authorisation to carry forward tax losses for more than five tax periods. Its transfer pricing provisions address transaction comparability, arm’s length pricing, documentation, price adjustments and advance pricing agreements. This guide focuses on the rules relevant to businesses operating in or through Rwanda.1
Who may be affected
Transfer pricing rules examine transactions between related persons. Rwanda’s earlier framework also included transactions between resident related persons and certain dealings between a resident and a person in a beneficial tax regime, whether or not the parties were related. PwC’s 2026 alert describes the new Order as building on that earlier framework and reports that the rules continue to create exposure for some transactions involving low-tax jurisdictions.3,4
Under the earlier definition described by PwC, a beneficial tax regime could include a jurisdiction with no income tax or a maximum rate of 20%, tax breaks for non-residents, limited requirements for substantial economic activity, low or no tax on foreign income, or restricted access to information about ownership and corporate structures. PwC’s 2026 alert reports that the relevant threshold for some transactions with unrelated parties in such regimes changed from 20% to 15%.3,4
The practical implication is that a business should map its transactions as well as its group relationships. PwC highlights procurement, services, financing, intellectual property and intermediary arrangements as areas where a Rwanda connection or a low-tax jurisdiction may warrant attention. The precise treatment depends on the legal conditions applying to the transaction.4
The arm’s length principle
The arm’s length principle asks whether the price and conditions of a controlled transaction match those independent parties would agree in comparable circumstances. The 2026 Order has separate provisions on comparable transactions, comparability factors, arm’s length prices and adjustments. These topics make the transaction itself and the basis for comparison central to a transfer pricing analysis.1
A pricing file should be consistent with the actual arrangement. PwC’s discussion of the 2026 rules describes increased attention to commercial rationale, the control of relevant risks and whether the return reflects economic reality. For example, an agreement or invoice may not, by itself, explain the work performed, the commercial purpose of a charge or the role of the party earning the income.4
The Order includes a provision on disregarding a controlled transaction for tax purposes. PwC explains that the earlier rules allowed this where the arrangement differed from what independent parties acting rationally would have adopted in comparable circumstances, and that the 2026 framework reinforces this area. The possibility of a challenge makes evidence of the transaction’s business purpose important.1,4
Recognised pricing methods
The 2026 Order names five methods for determining arm’s length prices. It also includes provisions on alternative methods, selection of the tested party and the arm’s length range. The method names are set out below; the Order’s article headings show where each method is addressed.1
Methods listed in the Order and their article references.1
| Method | Order article |
|---|---|
| Comparable uncontrolled price | Article 9 |
| Resale price | Article 10 |
| Cost plus | Article 11 |
| Transactional net margin | Article 12 |
| Transactional profit split | Article 13 |
Source: Official Gazette of the Republic of Rwanda: Ministerial Order No. 003/26/10/TC on transfer pricing and simplified accounting (April 2026)1
PwC describes the five methods as familiar methods retained in the updated framework. A taxpayer’s analysis should connect the chosen approach to the transaction and the supporting evidence. The Order also names an alternative method, so the five listed methods are not the only method-related provision in the instrument.1,4
Documentation and filing
Documentation requirements appear in Articles 17 to 20 of the 2026 Order, covering documentation, preparation timing, taxpayers discharged from the preparation obligation and sources of information on comparable transactions. Under the earlier framework, PwC described transfer pricing policies and documentation as supporting related-party transactions. EY’s 2026 alert identifies organizational structure, financial statements, benchmarking analyses, intercompany agreements and supporting information among the minimum content under the earlier rules.1,2,3
Thresholds and submission procedures described in the cited guidance.2
| Requirement | What the guidance describes |
|---|---|
| Turnover | EY’s 2026 alert identifies annual turnover exceeding RWF 600 million among the thresholds for filing documentation. |
| Controlled transactions | The same alert identifies more than RWF 10 million for an individual transaction or more than RWF 100 million in aggregate. |
| eTax submission | The RRA’s platform was updated to accept documentation as an annex to the annual corporate income tax declaration. |
| Earlier request process | Before the filing mechanism was available, documentation was maintained and supplied within seven days of a written request. |
Source: EY: Rwanda introduces transfer pricing documentation filing via eTax (April 2026)2
EY reports that the eTax enhancement followed the financial-year 2025 corporate income tax filing deadline and shifted the process from submission only on request to proactive filing for taxpayers meeting the prescribed thresholds. The alert also recommends that affected groups consider reviewing financial years 2023 to 2025 and uploading documentation where appropriate. Treat that as EY’s compliance recommendation, distinct from the statutory filing requirements.2
A practical preparation sequence:2,3
- Map related-party transactions and consider whether any dealings with a person in a beneficial tax regime may also be in scope.
- Gather contracts, invoices, transaction records, relevant financial information and evidence of what was supplied or performed.
- Prepare the transfer pricing analysis and supporting documentation in line with the applicable rules and filing requirements.
- Check the controlled-transaction schedule and group structure information required for the relevant income tax declaration.
- Submit documentation through eTax where the filing requirement applies; keep the records available for any RRA enquiry or audit.
Source: EY: Rwanda introduces transfer pricing documentation filing via eTax (April 2026); PwC Rwanda: Rwanda’s new Transfer Pricing guidelines go further than the usual (February 2021)2,3
Advance pricing agreements
An advance pricing agreement, or APA, allows a taxpayer to seek agreement in advance on transfer pricing matters. The 2026 Order dedicates Articles 25 to 31 to APAs. The provisions cover who may apply, the application and its modalities, application requirements, rejection, the agreement’s duration and cancellation.1
For a business considering an APA, the provisions make the application process and supporting requirements important starting points. Prepare a clear account of the transactions concerned and the pricing approach, and identify the relevant group entities and commercial arrangements. The Order’s APA chapter is the applicable reference for eligibility and procedure.1
Audits and practical controls
Transfer pricing audits form part of Rwanda’s tax administration framework. EY’s summary of the 2023 Tax Procedures Law identifies transfer pricing audits as a recognised audit type and describes audits of controlled transactions between related parties as a means of checking compliance with the arm’s length principle. The 2026 Order provides the related pricing and documentation framework.1,5
PwC’s 2026 alert identifies service charges without evidence of actual services, management fees without demonstrable benefit, intermediary companies without meaningful activity, and financing arrangements where the income-earning party does not control the relevant risk as examples that may attract scrutiny. These are not automatic findings of non-compliance; they illustrate why a file should explain the commercial arrangement as well as its price.4
Records that help explain the transaction include:4
- Agreements and invoices that match the services, goods or funds actually provided.
- Evidence of the business purpose and the recipient’s benefit from an intra-group service.
- Information showing which entity performed relevant work and made material decisions.
- The pricing analysis, financial data and supporting material used to reach the result.
- Consistent contracts, accounting entries and actual conduct.
Source: PwC: Rwanda’s new transfer pricing rules: The era of substance has arrived4
What to check before filing
Start with a transaction map that includes related parties and any dealings potentially treated as controlled because of a beneficial tax regime. Confirm which documentation and declaration requirements apply to the tax year, including whether the turnover and transaction thresholds described in EY’s 2026 alert are met. Prepare the analysis early enough to support the tax declaration and the eTax submission process.2,3
Keep the transfer pricing file aligned with the underlying commercial arrangements. Where an APA may be useful, review the relevant chapter of Ministerial Order N° 003/26/10/TC. Check the RRA’s current requirements for the tax year before filing or responding to an audit notice.1,2
Frequently Asked Questions
Which rules govern transfer pricing in Rwanda?
The current instrument is Ministerial Order N° 003/26/10/TC, dated 29 April 2026. It sets out Rwanda’s transfer pricing framework, including comparability, the arm’s length principle, pricing methods, documentation and advance pricing agreements. The Tax Procedures Law also provides for transfer pricing audits.
What does the arm’s length principle mean?
It means that the price and conditions of a covered transaction should reflect what independent parties would agree in comparable circumstances. The analysis concerns the transaction and its comparables. Rwanda’s 2026 Order includes provisions on comparability factors, arm’s length prices and adjustments.
Which pricing methods does Rwanda recognise?
The 2026 Order names the comparable uncontrolled price, resale price, cost plus, transactional net margin and transactional profit split methods. It also includes provisions on alternative methods, tested-party selection and the arm’s length range. The method names appear in Articles 9 to 13.
Can transactions with unrelated parties be covered?
Some transactions with unrelated parties may be relevant where a counterparty is in a beneficial tax regime. PwC’s 2026 alert reports that the threshold for certain transactions in such regimes changed from 20% to 15%. Businesses should consider the jurisdiction and the legal conditions, not only whether the counterparty is related.
Does Rwanda require transfer pricing documentation to be filed?
EY reported in April 2026 that the RRA’s eTax platform had been updated to accept transfer pricing documentation as an annex to the annual corporate income tax declaration. Its alert describes the requirement as applying when prescribed thresholds are met. Confirm which filing requirements apply to the tax year concerned.
What thresholds are mentioned for transfer pricing filing?
EY’s April 2026 alert identifies annual turnover exceeding RWF 600 million, individual controlled transactions exceeding RWF 10 million, or aggregate controlled transactions exceeding RWF 100 million among the relevant thresholds. The alert links these figures to documentation filing. Check their application to your circumstances and tax year.
What happened to the seven-day documentation deadline?
The seven-day period was the earlier process for providing documentation after receiving a written request from the RRA. EY reported that the 2026 eTax enhancement introduced submission with the annual corporate income tax declaration for taxpayers meeting prescribed thresholds. The request-based process should therefore not be treated as the only filing consideration.
Sources
- Official Gazette of the Republic of Rwanda: Ministerial Order No. 003/26/10/TC on transfer pricing and simplified accounting (April 2026)
- EY: Rwanda introduces transfer pricing documentation filing via eTax (April 2026)
- PwC Rwanda: Rwanda’s new Transfer Pricing guidelines go further than the usual (February 2021)
- PwC: Rwanda’s new transfer pricing rules: The era of substance has arrived
- EY: Rwanda gazettes new Tax Procedures Law (April 2023)
Figures checked 10 November 2026. Prepared by InvestRwanda.com for general information. It is not investment, tax or legal advice; please confirm details with a qualified adviser before acting.
