Holdings, funds and regional headquarters

KIFC is promoted by Rwanda Finance Ltd, a government-owned company. It is a framework, not a separate territory: a holding company in KIFC is an ordinary Rwandan company, registered with the Office of the Registrar General (ORG), which then registers as an investor with the Rwanda Development Board (RDB) and meets the substance conditions attached to its rate.

Three things make the offer coherent. First, reduced rates in Law N° 006/2021 of 05/02/2021 on investment promotion and facilitation, administered through investment registration. Second, a modern set of vehicle laws, including Law N° 062/2021 on collective investment schemes, Law N° 063/2021 on trusts and Law N° 059/2021 on foundations, all dated 14/10/2021. Third, Rwanda’s position inside the East African Community and the African Continental Free Trade Area, with a treaty network that reaches the Gulf, Luxembourg, Belgium, Mauritius and Singapore.

The offer also has limits. The rates depend on substance that costs money every year. The treaty network is short. Rwandan rules on transfer pricing and your home country’s anti-avoidance rules both look at low-taxed entities. This page sets out the rates, the vehicles, the conditions and the risks in that order.

Investment law

Law N° 006/2021 of 05/02/2021 on investment promotion and facilitation sets the incentive rates, including the 3% and 0% regimes. It replaced the 2015 investment law. Art. 12 guarantees repatriation, after tax, of capital, profits, loan principal and interest, and liquidation proceeds. Art. 18 gives RDB 2 working days to decide on investment registration.

Collective investment schemes

Law N° 062/2021 of 14/10/2021 replaced Law N° 40/2011. It recognises four forms of scheme: the unit trust scheme, created by trust deed between operator and trustee, without legal personality; the investment company scheme, with fixed or variable capital or as a protected cell company; the partnership scheme, normally a limited partnership; and the contractual scheme between operator and depositary. Each must be approved by the capital market regulator. The law also covers recognition of schemes established outside Rwanda (Art. 23) and licensing of operators, managers, trustees, depositaries and custodians.

Trusts

Law N° 063/2021 of 14/10/2021 governing trusts lets a natural person or a corporation act as trustee. Professional trustees and trust service providers are licensed (Art. 38): by the Capital Markets Authority for trusts within capital market laws, otherwise by the National Bank of Rwanda (Art. 3). Trust instruments and trust property are registered (Art. 34), and beneficial owners are recorded with the Registrar General (Art. 85). A trust may last up to 99 years (Art. 17).

Foundations

Law N° 059/2021 of 14/10/2021 governing foundations creates a separate legal person with a charter, a council and, where relevant, a guardian. Its name ends with “Foundation”. It acquires legal personality on registration. Foundations formed abroad can extend activities to Rwanda or re-domicile there.

Companies

Holding companies and SPVs are formed under Law N° 007/2021 of 05/02/2021 governing companies, as amended by Law N° 019/2023. Beneficial owners holding 25% or more of shares or votes are declared to the Registrar General; changes are notified within 14 days.

Foreign experts who move to Rwanda to work for a KIFC-licensed entity are exempt from personal income tax on their foreign-source income for five years. Rwandan employment income is still taxed under the usual monthly PAYE bands, from 0% up to RWF 60,000 to 30% above RWF 200,000, and RSSB contributions apply to foreign staff on the same basis as to Rwandans.

Relocated staff need permits. Investor permits are issued by sector category, such as W1 for IT and Z1 for other sectors, at RWF 150,000 for up to two years; employees use H1 or H2 employment permits. The investment registration certificate for USD 250,000 invested also allows the recruitment of three foreign employees without a labour-market test.

Substance slips

The substance tests are measured continuously. Net assets fall below USD 1 million after a distribution, a local professional resigns, the office lease lapses: any of these can put the 3% rate at risk for the year. We review the tests before each year end and before any large distribution.

Transfer pricing

Ministerial Order N° 003/26/10/TC on transfer pricing requires arm’s-length pricing between related parties and uses a 15% threshold to identify low-tax jurisdictions. It also provides for advance pricing agreements. Intra-group loans, guarantees, management fees and IP licences to and from a KIFC entity need documentation that explains the price. The corporate income tax return is filed with transfer pricing documentation.

Home-country rules

Many countries tax low-taxed foreign subsidiaries in the hands of their parent or controlling individuals under controlled foreign company rules. A 3% Rwandan rate is low by any standard. Groups with consolidated revenue of EUR 750 million or more also need to look at global minimum tax rules. Neither question is answered in Kigali; we coordinate with your home adviser.

Currency and pricing

Domestic transactions are in Rwandan francs under BNR Regulation 42/2022 as amended by Regulation 89/2025. A holding company mostly moves money across borders, which runs through authorised banks, but its local costs, rent and salaries are paid in RWF.

Changing law

Income tax law has been amended twice since 2022: Law N° 051/2023 lowered CIT to 28%, and Law N° 014/2025 raised capital gains tax to 10%. Incentive regimes can change too. Registered investors should keep their investment certificate current and watch for amendments.