Rwanda Case Law

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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BHARAT HEAVY ELECTRICALS Ltd vs IKIGO CY’IMISORO N’AMAHORO (RRA)

Court

Court of Appeal

Case number

RS/REV/RCOM 00002/2022/CA

The Court of Appeal held that Bharat Heavy Electricals Ltd had not shown the documents were new evidence, so its review application was inadmissible.

• Review of judgment
• New evidence
• Corporate taxation
• Withholding tax
• Vat
• Costs and attorney fees

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IMIRONGO CoA - No 5 - Febuary -2023

Court

Court of Appeal

The Court of Appeal established binding principles on calculation of appeal deadlines, mandatory payment of withholding tax, distinction between civil and commercial acts, contract classification, recusal standards, sentencing discretion and mitigation, procedural limits on appellate arguments, modification of charges, proportionality in drug sentencing, and retroactive application of interpretive ministerial orders.

Source excerpt

• Sexual offenses against minors
• Withholding tax
• Civil liability (responsabilité civile)
• Recusal of judges
• Appeal deadlines
• Mitigating circumstances

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BHARAT V RRA

Court

Court of Appeal

Case number

RCOMAA 00023/2021/CA

The Court of Appeal upheld tax assessments against Bharat Heavy Electrical Ltd, finding no proof of a separate equipment sale outside Rwanda and awarding partial costs to RRA.

• Corporate taxation
• Withholding tax
• Vat
• Territoriality of tax
• Contract interpretation
• Tax-law

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GAKIRE v NDAGIJIMANA

Court

Court of Appeal

Case number

RCOMAA 00048/2022/CA

The Court of Appeal held that a Mauritian company without a permanent establishment in Rwanda was not subject to the 15% withholding tax, but interest on the refund was not due.

• Double taxation
• Withholding tax
• International tax treaties
• Jurisdiction
• Procedural law
• Double-taxation

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IMIRONGO CoA Booklet no 5

Court

Court of Appeal

The Court of Appeal established that procedural fairness requires appeal periods to be calculated from the date judgment reading minutes are entered into the official system if there is a delay, not from the oral pronouncement. Withholding tax obligations apply regardless of explicit mention in judgments. The distinction between commercial and civil acts depends on the nature and purpose of the act, not the status of the actor. Recusal of judges requires objective evidence of bias existing before the case. Sentencing must consider proportionality and mitigating factors, allowing for reduction…

Source excerpt

• Sexual offenses against minors
• Withholding tax
• Civil liability (responsabilité civile)
• Recusal of judges
• Sentencing principles
• Appeals procedure

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RRA vs SDV RTANSAMI

Court

Supreme Court

Case number

RCOMA 0156/12/CS

SDV TRANSAMI Rwanda was obliged to withhold and pay 15% tax on loan interest paid to STANBIC Bank Kenya for 2008 and 2009, as the obligation arises from the law in force at the time, and failure to withhold makes the payer liable. However, depreciation must be allowed on concrete paved land for tax computation, and the tax must be recomputed accordingly. Damages and procedural fees are not awarded as both parties lost in part.

Source excerpt

• Withholding tax
• Interpretation of multilingual statutes
• Tax penalties
• Depreciation in tax computation
• Non-retroactivity of tax law
• Damages and procedural fees

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CORAR v. IKIGO CY’IMISORO N’AMAHORO

Court

Supreme Court

Case number

RCOMA 0127/11/CS

The Supreme Court of Rwanda upheld tax assessments on insurance dossier fees, employee lunch benefits, and withholding-tax penalties, while awarding RRA damages.

• Value added tax (vat)
• Direct income tax
• Withholding tax
• Employee benefits taxation
• Tax penalties
• Value-added-tax

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NEW AFRICA GAMING (NAG) v. RRA

Court

Supreme Court

Case number

RCOMA 0039/12/CS

The Supreme Court upheld a tax assessment against New Africa Gaming, holding that its lottery activities were taxable and that RRA could rely on available records.

• Withholding tax
• Value added tax
• Paye
• Gambling regulation
• Tax assessment
• Tax exemptions

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RWANDA REVENUE AUTHORITY v. AGESPRO SECURITY

Court

Commercial High Court

Case number

RWANDA REVENUE AUTHORITY V. AGESPRO SECURITY

The Commercial High Court dismissed RRA’s appeal, holding that the tax audit notice was not properly proven, prescription was not interrupted, and the dispute was insufficiently particularized.

• Tax assessment
• Prescription of tax audit
• Burden of proof
• Withholding tax
• Notification by registered mail
• Tax-assessment

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