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06 September 2018 Rwanda issues guidelines on management, technical services and royalty fees paid to nonresidents On 29 August 2018, the Commissioner General of the Rwanda Revenue Authority issued a public ruling (the ruling) which provides guidance on the tax deductibility of management, technical services and royalty fees. Under Article 26 of the Law No. 016/2018 of 13 April 2018 establishing taxes on income, management, technical services and royalty fees paid by a taxpayer to a nonresident person exceeding 2% of the taxpayer's turnover are not tax deductible. a) The management, technical services and royalty fees paid to a nonresident related person are determined based on the total amount of payments in a tax period.
b) Management fees refers to any payment of any kind to any person, other than to an employee of the person making payments, in consideration for any service of a technical, managerial and professional or consultancy in nature. c) A royalty is a payment of any kind paid as a consideration for the use of, or the right to use, any copyright of literacy, craftsmanship, artistic or scientific work including cinematograph films, or tapes used for radio or television broadcasting, any patent, trade mark, design or model, computer application, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific knowledge. Document ID: 2018-6058 |