Rwanda Case Law

IMIRONGO CoA - No 28 September - October 2025

Court

Court of Appeal

A notarial will is invalid if secrecy is breached by disclosure to a beneficiary before the testator's death, as this contravenes the requirement for confidentiality under Rwandan succession law. In tax matters, a second audit following annulment of the first for procedural errors does not require explicit mention in the annulment decision. In criminal cases, mitigation of sentence is discretionary and must be justified by the court, which is not bound to reduce the sentence even if mitigating factors are present. Confessions and witness statements retain evidentiary value subject to judicial…

Source excerpt

• Wills and succession
• Tax appeals
• Criminal sentencing
• Appeals procedure
• Evidence assessment
• Mitigating circumstances

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EUROWORLD RENT-A-CAR LTD v. RRA

Court

Court of Appeal

Case number

RCOMAA 00013/2025/CA

The Court held that under Article 44 of Law No. 026/2019, when a tax audit is annulled due to errors by RRA, a new audit may be conducted without explicit authorization in the annulment decision. Notification of fault by email is valid and does not require a physical signature if the taxpayer acknowledges receipt. RRA provided sufficient evidence for the assessment. EUROWORLD RENT-A-CAR Ltd's services were not exempt as principal transport services but were taxable car rental services. The appeal was dismissed and the previous judgment upheld.

Source excerpt

• Withholding tax
• Tax audit procedure
• Tax appeals
• Transport services tax exemption

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SOFATHEBE LTD v RRA

Court

Commercial High Court

Case number

RCOMA 00061/2022/HCC

The Commercial High Court dismissed SOFATHEBE Ltd’s appeal, holding that a second identical tax appeal did not extend the response period and that RRA could be awarded costs.

• Tax appeals
• Procedural deadlines
• Costs and attorney fees
• Tax-appeals
• Procedural-deadlines
• Costs-and-attorney-fees

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AIRTEL RWANDA LTD v. RWANDA REVENUE AUTHORITY

Court

Commercial High Court

Case number

RCOMA 00137/2018/CHC/HCC

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…

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• Corporate loss carry-forward
• Shareholding change and tax consequences
• Corporate restructuring
• Tax appeals

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

Court

Supreme Court

Case number

RCOMAA 00055/2016/SC

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.

Source excerpt

• Value added tax (vat)
• Income tax
• Tax penalties
• Public procurement
• Advance payments
• Tax appeals

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