Executive summary

In April 2026 Rwanda Revenue Authority (RRA) introduced enhancements to its electronic tax-filing system (eTax) platform, which now allows for submission of transfer pricing documentation (TPD) as part of the annual Corporate Income Tax (CIT) declaration process.

Taxpayers engaging in related-party transactions are now required to formally submit TPD as part of their CIT declarations, marking a shift from the prior "upon request" regime. The filing requirement applies to taxpayers meeting prescribed thresholds, including entities with annual turnover exceeding 600 million Rwandan francs (FRW600m) and controlled-transaction thresholds of FRW10m per transaction or FRW100m in aggregate.

Detailed discussion

Legal and regulatory framework

Article 32 of Law No. 027/2022 of 20 October 2022 on Establishing Taxes on Income (Income Tax Law) requires taxpayers engaged in controlled transactions with related parties to maintain documentation supporting compliance with the arm's-length principle.

In addition, Article 16 of Law No. 020/2023 of 31 March 2023 on Tax Procedures (Tax Procedures Law) requires taxpayers with related-party transactions to submit TPD alongside their annual CIT declarations, if applicable thresholds are met. The documentation must be prepared in accordance with Article 32 of the Income Tax Law and Ministerial Order No. 003/20/10/TC of 11 December 2020 establishing General Rules on Transfer Pricing. Although these provisions became effective on 31 March 2023, there was no practical mechanism to facilitate submission of TPD. Historically, taxpayers that met the prescribed requirements were required to maintain TPD and submit to TPD to the RRA within seven days of a request from the tax administration.

Article 17 of the Tax Procedures Law prescribes the minimum content of the TPD, including organizational structure, financial statements, benchmarking analyses, intercompany agreements and other relevant supporting information.

Introduction of eTax submission mechanism

The RRA has now updated the eTax platform to allow taxpayers to upload TPD as an annexure to the CIT declaration. This enhancement, introduced after the FY 2025 CIT filing deadline, marks a shift to a proactive filing obligation from the previous requirement that TPD must only be submitted upon request (within seven days of a written notice from the RRA).

Implications for taxpayers

Taxpayers meeting the transfer pricing (TP) thresholds should:

• Assess their transfer pricing compliance obligations
• Ensure that TPD is prepared in accordance with applicable legal requirements
• Consider revising previously filed CIT returns for FY 2023 to FY 2025 to upload TPD, including all prescribed annexures, via eTax

If CIT returns were filed on time and no changes are made to the reported figures, penalties may not be imposed, although this is not explicitly guaranteed.

Increased enforcement focus

Note also that the Tax Administration has intensified its focus on transfer pricing compliance, with the Tax Procedures Law, 2023 explicitly providing for transfer pricing audits as part of the RRA's audit framework.

Next steps

Taxpayers should take immediate corrective action to review their transfer pricing positions, ensure that documentation is complete and contemporaneous, and regularize prior-year filings where necessary, particularly by revising FY 2023 to FY 2025 CIT declarations by uploading the corresponding TPD. Early action may mitigate potential exposure to noncompliance penalties as enforcement intensifies.

Affected entities should consult with qualified local tax professionals for support with transfer pricing risk assessments, preparation, updating and/or review of TP documentation, including local and master files and benchmarking studies, as well as country-by-country reporting, assistance with eTax submissions and TP audit engagement with the RRA.