AIRTEL RWANDA LTD v. RWANDA REVENUE AUTHORITY
A 100% change in shareholding and voting rights in a company whose shares are not traded on a recognized stock exchange constitutes a substantive change under Article 29(3) of Law No 16/2005, precluding the carry-forward of losses. The company continued to exist and was not deregistered, so the exception for full acquisition and deregistration does not apply. The existence of a recognized stock exchange is not limited to Rwanda, and the law applies as long as a recognized exchange exists anywhere. The appellant's arguments regarding mere correction of records and lack of substantive change ar…
Source excerpt
- Corporate loss carry-forward
- Shareholding change and tax consequences
- Corporate restructuring
- Tax appeals