Rwanda has introduced significant changes to its transfer pricing framework through Ministerial Order Nº 003/26/10/TC of 29 April 2026, reshaping compliance expectations for businesses engaged in related-party and cross-border transactions.

Our latest tax alert provides a concise analysis of the most notable developments, including the operationalisation of Advance Pricing Agreements (APAs), expanded transfer pricing documentation requirements, increased scrutiny of financing and intermediary arrangements, and revised beneficial tax regime thresholds.

The alert offers insights on:

• the structure and application of the new APA framework
• evolving Local File and Master File expectations
• transfer pricing implications for financing, guarantees and restructurings
• documentation standards expected by the Rwanda Revenue Authority (RRA)
• areas likely to attract increased regulatory attention

This publication is essential reading for tax professionals, multinational groups, finance leaders and businesses seeking to strengthen transfer pricing governance and proactively manage compliance risk in Rwanda’s changing tax environment.