Rwanda - Local Requirements

Source:

• Law nº 027/2022 of 20 October 2022 establishing taxes on income (as amended), Articles 14, 31, and 32
• Ministerial Order nº 003/26/10/TC of 29 April 2026 relating to transfer pricing, simplified accounting method, and authorisation granted to a taxpayer to carry forward loss for more than five tax periods (Official Gazette n° Special of 29/04/2026), Chapter II, Articles 2–24

Summary of local requirements

Strict Format: Not specified; the TPD annexure must be uploaded in PDF format via the RRA eTax portal

Language: Kinyarwanda, English, and French

To download the legislation in the original language, go to:

• https://cdn.aibidia.com/localization/Rwanda_Law.pdf
• https://cdn.aibidia.com/localization/Rwanda_Order.pdf
  

Transfer Pricing Local File ("Local File")

The transfer pricing local file includes at least the following information:

(a)	An overview of the taxpayer's business operations and their organisation;
(b)	A description of the corporate legal group structure to which the taxpayer is a member and the corporate group's operational structure;
(c)	A general description of multinational enterprise business including – (i) Important drivers of business profit; (ii) A description of the supply chain for the group's five largest products or service offerings by turnover plus any other products or services amounting to more than 5% of group turnover; (iii) A detailed description of the business strategy pursued by the taxpayer including an indication whether the taxpayer has been involved in or affected by business restructurings or intangible transfers in the present or immediately preceding year and an explanation of such aspects on transactions that affect the taxpayer; (iv) A list of the taxpayer's key competitors in Rwanda for each material category of controlled transactions in which the taxpayer is involved; (v) A description of the controlled transactions and the context in which such transactions took place including an analysis of the comparability factors; (vi) Detailed functional analysis showing the functions performed, risks assumed and assets used by the taxpayer and its related persons for each category of controlled transaction; (vii) Detailed comparability analysis in respect of each category of the controlled transaction with potential uncontrolled comparable transactions including the search process for comparable, data source, selection criteria and rationale for rejecting potential comparable; (viii) A list and description of selected comparable uncontrolled transactions, if any, and the relevant information of those comparable including financial data, and agreements; (ix) An explanation of the reasons given for the selection of most appropriate transfer pricing method, the selection of the tested party and the financial indicator; (x) A summary of financial information used in applying the transfer pricing method, including – (A) Annual local entity financial accounts for the fiscal year concerned; (B) Information and allocation schedules showing how the financial data used in applying the transfer pricing method may be tied to the annual financial statements; (C) Summary schedules of relevant financial data for comparable used in the analysis and the sources from which that data was obtained; (xi) An explanation of the reasons for performing a multi-year analysis if any; (xii) Details of any advance pricing agreements or similar arrangements in other countries that are applicable to the controlled transactions; (xiii) A comparability analysis that includes: (A) A description of the process undertaken to identify uncontrolled comparable transactions; (B) An explanation of the basis for the rejection of any potential internal uncontrolled comparable transactions; (C) A description of the uncontrolled comparable transactions; (D) An analysis of comparability of the controlled transactions and the uncontrolled comparable transactions; (E) Detailed information on any comparability adjustments made; (xiv) Details of any industry analysis, economic analysis, budgets or projections relied on; (xv) A conclusion as to consistency of the conditions of the controlled transactions with the arm's length principle, including details of any adjustment made to ensure compliance; (xvi) Information and allocation schedules showing how the financial data used in applying the transfer pricing method may be tied to the annual financial statements; (xvii) A summary of schedules of relevant financial data for comparable used in the analysis and the sources from which that data was obtained.

Recommendations for Local File:

Regarding content requirements:

• Key Competitors per Transaction Category:

  Rwanda requires a list of the taxpayer's key competitors in Rwanda specifically for each material category of controlled transactions — a more granular requirement than the standard entity-level competitor list.

  We recommend documenting the competitors relevant to each transaction category in the Main Customers & Competitors tab of the Legal Entities section, and where the competitor landscape differs across transaction categories, noting the transaction-specific competitor context in the Application Assumption column within the Methods tab of the corresponding Reporting Level.

• Industry Analysis, Economic Analysis, Budgets, and Projections:

  Rwanda explicitly requires documentation of any industry analysis, economic analysis, budgets, or projections that were relied on in preparing the transfer pricing analysis.

  We recommend documenting the industry and economic analysis in the Business Description subsection of the Entity Description tab, and saving any budgets, projections, and supporting economic studies in the Resources section for attachment to the Local File.

• Supply Chain for Top Products/Services:

  Rwanda requires a description of the supply chain for the group's five largest products or service offerings by turnover, plus any other products or services exceeding 5% of group turnover.

  We recommend documenting the supply chain and main geographic markets for all qualifying products and services in the Supply Chains section.

• Controlled Transactions Schedule:

  Rwanda requires a controlled transactions schedule prepared in the prescribed model form (Annex 1 of the Ministerial Order), to be submitted via the RRA eTax portal alongside the annual income tax declaration.

  We recommend preparing the Local File content using TPDoc's standard functionality, and contacting the Aibidia support team to assist with the preparation of the controlled transactions schedule in the prescribed Annex 1 model form for submission via the RRA eTax portal.

Regarding format/structural requirements:

Rwanda does not prescribe a strict narrative template for the Local File. However, the TPD annexure must be uploaded in PDF format via the RRA eTax portal, and the controlled transactions schedule must be submitted in the prescribed Annex 1 model form. Documentation must be prepared before the deadline for filing the income tax return and provided to the RRA within seven days of a written request.

We recommend preparing the Local File using TPDoc's standard Local File functionality. The Local File may be prepared in Kinyarwanda, English, or French.

Master File

Rwanda has not issued specific content requirements for the Master File. Rwanda's Ministerial Order nº 003/26/10/TC of 29 April 2026 requires MNE groups to maintain a Master File and submit it alongside the annual CIT return via the RRA eTax portal, but defers to the OECD BEPS Action 13 standard for its content.

 

Recommendations for Master File:

Regarding content requirements:

Rwanda has not published specific content requirements for the Master File. 

We recommend referring to the OECD Transfer Pricing Guidelines (Chapter V, Annex II — Master File) when preparing the Master File, as Rwanda's framework is aligned with the OECD BEPS Action 13 standard. TPDoc's standard Master File functionality covers all OECD-required sections.

Regarding format/structural requirements:

Rwanda does not prescribe a strict standardised narrative template for the Master File. The Master File must be submitted in PDF format via the RRA eTax portal alongside the annual corporate income tax return, and must also be available for submission to the RRA within seven days of a written request.

We recommend preparing the Master File using TPDoc's standard Master File functionality. The Master File may be prepared in Kinyarwanda, English, or French.