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Rwanda Case Law

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Tax law

INGUFU GIN LTD v. RWANDA REVENUE AUTHORITY

Urukiko rw’Ubujurire rwatesheje agaciro umusoro kuri 41.971.000 Frw, rwemeza ko wari washatsewa umusoro mbere; rwemeza ariko ko 450.114.953 Frw na 996.101.280 Frw bigomba gusoreshwa.

  • Burden of proof
  • Income tax
  • Value added tax
  • Excise duty
  • Tax assessment
  • Accounting evidence
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Tax law RLR V.4-2018

FOREST COMPANY VOLCANOES GORILLAS (FCVG) Ltd v IKIGO CY’IMISORO N’AMAHORO (RRA)_kn

Advance payments ('avance de démarrage') received by a contractor under a public procurement contract are not subject to VAT or income tax as they do not constitute payment for completed work and are refundable; penalties for late VAT registration must exclude such advance payments; however, FCVG Ltd failed to provide proper accounting, justifying taxation by estimation at a 21% profit margin, and evidence supported a 100% penalty for tax evasion. Legal fees are not awarded as both parties partially succeeded.

  • Value added tax (vat)
  • Income tax
  • Tax penalties
  • Public procurement
  • Advance payments
  • Tax appeals
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Tax law RCOMAA 0014/14/CS

IKIGO CY’IMISORO N’AMAHORO v. MUNYABARAME

The Supreme Court held that tax equity did not require comparing the taxpayer with differently situated traders, and restored the higher tax assessment.

  • Income tax
  • Value added tax
  • Tax assessment
  • Tax equity
  • Damages
  • Legal costs
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Tax law RLR V.1-2017

RWANDA REVENUE AUTHORITY v. MUHIRE_231198_en

The Supreme Court held that a genuine loan is not taxable income, upheld a VAT limitation defence as public order, and confirmed advocate fees.

  • Income tax
  • Business profit
  • Taxable income
  • Loan exclusion from taxable income
  • Statute of limitation
  • Value added tax
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Tax law RLR V.1-2017

IKIGO CY’IMISORO N’AMAHOORO (RRA) v. MUHIRE

The Supreme Court held that a 10,177,083 Frw advance was a loan, not taxable income, and that Muhire could raise VAT limitation as a defense. RRA’s appeal failed.

  • Income tax
  • Value added tax
  • Statute of limitations
  • Deductibility of loans
  • Attorney fees
  • Income-tax
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Tax law RCOMA 0177/12/CS

SORECO Ltd v. RRA

The Supreme Court of Rwanda dismissed SORECO Ltd’s appeal, holding that its challenge to an income tax assessment was filed too late and that no valid suspensive condition applied.

  • Tax assessment
  • Appeals procedure
  • Vat
  • Income tax
  • Procedural time limits
  • Tax-law
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Tax law RCOMA 0029/12/CS

Quincaillerie du Nil v. Rwanda Revenue Authority

The Supreme Court upheld a tax assessment against Quincaillerie du Nil, finding it failed to distinguish its company account from the owner’s personal account.

  • Income tax
  • Value added tax
  • Tax assessment
  • Corporate vs personal account distinction
  • Income-tax
  • Value-added-tax
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Tax law RCOMA 0060/12/CS

NKUBIRI v. IKIGO CY’IMISORO N’AMAHORO

The Supreme Court held that NKUBIRI failed to prove a deductible loss of 75,000,000 RWF and that penalties had to be calculated under the law in force for 2004-2008.

  • Income tax
  • Tax assessment
  • Tax penalties
  • Loss deduction
  • Tax-law
  • Income-tax
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Rwanda decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.