IHS RWANDA LTD vs IKIGO CYâIMISORO NâAMAHORO (RRA)
The USD 200,000,000 advanced by IHS Mauritius Rwanda Ltd to IHS Rwanda Ltd did not meet the legal criteria for a loan (no interest, no security, no repayment schedule) and was therefore equity, not debt. Consequently, foreign exchange losses on this amount were not deductible. Depreciation on tower components (batteries, cables, lights) was properly calculated at 10% as they are telecommunications assets with a lifespan over 10 years. Losses from 2015 were not properly appealed to the Commissioner General and could not be judicially reviewed. IHS Rwanda Ltd was not entitled to costs or attornâŚ
Source excerpt
- Corporate taxation
- Foreign exchange losses
- Depreciation of assets
- Shareholder loans
- Procedural requirements in tax appeals