TUMWESIGE vs EAR DIOCÈSE DE BYUMBA
The USD 200,000,000 advanced by IHS Mauritius Rwanda Ltd to IHS Rwanda Ltd did not meet the legal requirements of a loan—lacking interest, security, and a clear repayment schedule—and thus constituted equity, not debt. Consequently, foreign exchange losses claimed on this amount were not deductible. Depreciation on tower components (batteries, cables, lights) was correctly calculated at 10% as they are part of telecom assets with a lifespan over 10 years, and IHS Rwanda Ltd failed to prove otherwise. The 2015 loss of 4,369,743,840 Frw was not properly appealed to the Commissioner General and…
Source excerpt
- Corporate taxation
- Foreign exchange losses
- Depreciation of assets
- Related party transactions
- Administrative appeals
- Procedural law