Restriction on Deductibility of Technical and Management Fees, and Royalties Paid to Non-Residents: Potential Conflict with Rwanda’s Obligations under Double Taxation Avoidance Treaties
The Rwandan Income Tax Act (Law nº 016/2018 of 13/04/2018) gazetted on April 16, 2018 overhauled the Rwandan income tax system with various significant changes. One of the changes introduced by the Rwandan Income Tax Act that gave rise to wide discussion among tax practitioners relates to non-deductible expenses—particularly the restriction imposed on the deductibility…