INVESTMENT & BUSINESS OPPORTUNITIES IN RWANDA

By Jean Pierre Tuyishime of FixLex Law Chambers and Pieter van Welzen of CMS South Africa

Introduction

Rwanda continues to be an attractive location for foreign investment. It is one of the world's fastest growing economies and has an enabling business environment, a growing private sector and large-scale infrastructure projects. Rwanda has developed industrial parks to accelerate the growth of investment, especially in manufacturing. Leading global businesses such as Volkswagen, Motorola Solutions, Andela and Radisson have established themselves in Rwanda. Recently, Mara Phones opened Rwanda's first smartphone factory. Knowledge institutions, like Carnegie Mellon University, have created campuses in Rwanda.

The country still has many untapped investment opportunities and ambitious policies and strategies for social and economic development. The purpose of this briefing is to provide an overview of the business and investment opportunities in Rwanda's key economic sectors, starting with a short description of the conditions for private investment.

Private investment

Rwanda has recently reformed its tax laws and enacted additional laws on insolvency, arbitration as well as a recent establishment of the financial intelligence centre. The latter is aimed at strengthening and protecting the financial integrity and an impetus for its rapidly growing economy. Cumulatively, these laws are designed to facilitate international business and to further improve the investment climate. It only takes six hours to start a business.

Personal income tax rates in Rwanda are progressive up to 30%. Corporate income tax rate is set at 30% and the VAT rate is 18%. Customs regulations are in line with the East African Customs Union (EACU) Agreement. Rwanda has adopted a 3-band duty structure for imports from outside of the EAC: finished products (25%); intermediate products (10%) and raw materials (0%).

Law n° 006/2021 of 05/02/2021 on investment promotion and facilitation provides various incentives to private investors. It identifies the following activities as priority economic sectors: (a) export, (b) manufacturing, (c) energy generation, transmission and distribution, (d) information and communication technologies, business process outsourcing and financial services, (e) mining activities, (f) transport, logistics and electric mobility, (g) construction or operations of specialised innovation or industrial parks, (h) affordable housing, (i) tourism, (j) horticulture and (k) film industry. The law ensures the repatriation of capital, profits derived from business activities, debt payments and interest on foreign loans, proceeds from the liquidation of investment, and other assets of the investor.

Incentives

Investors can benefit from various incentives, for example:

• A preferential corporate income tax rate of:
  •  0% for international companies with their head office or regional office in Rwanda
  • 3% for Rwanda based holding companies, collective investment schemes or investment SPVs
  • 3% on foreign sourced trading income for Rwanda based but internationally operating trading companies
  • 3% on foreign sourced royalties for Rwanda based IP companies
  • 15% for sectors, such as energy, transport, ICT, tourism, affordable housing and financial services
  • 15-25% for companies exporting goods and services
• A 7 year corporate income tax holiday for selected sectors, such as manufacturing, energy, ICT, health services and export related investment projects.
• Preferential withholding tax of 0% on interest, dividends and royalties for investors benefitting from the 3% and 15% preferential corporate income tax rate
• Accelerated depreciation of 50% for companies in sectors such export projects, manufacturing, telecommunications; agro-processing, education, health, transport and tourism
• Capital gains tax exemptions
• Expedited VAT refunds.

Opportunities

Below an overview is given of investment and business in a number of selected sectors.

Information & Communication Technology

Rwanda is promoting a progressive ICT sector as part of a strategy to become a ‘tech hub’ and has laid fibre optic broadband cables across the country. Kigali Innovation City, a flagship project with an investment value of USD 1.9 billion, is aimed at providing world class ICT infrastructure, products and services. It targets universities, international financial services companies, data centres, business continuity centres, agriculture & commodities, knowledge management.

Finance & Banking

Rwanda aims to become the financial hub of the region. It has recently established Kigali International Financial Centre (KIFC), an initiative that seeks to position Rwanda as a preferred financial jurisdiction for investments into Africa, as well as reform the domestic industry. Various international and regional commercial banks have an establishment in Rwanda. Opportunities include:

• • Investment banking services
  • Asset management
  • Insurance schemes  
  • Private equity funds
  • Venture capital and mutual funds.
  • Mortgage and agricultural banks
  • Brokerage activities (Rwanda Stock Exchange).

Agriculture

Rwanda’s economy is pre-dominantly dependent on agriculture and the sector is the principal contributor to employment creating jobs for about 80% of the population. Coffee and tea are the main sources of foreign exchange in the agriculture. The Government's policy is to diversify and increase productivity. Opportunities exist in food processing for domestic and international markets, mechanisation and the production of fruits and vegetables for the export, such as potatoes, French beans, peas, African egg plants, and fruits such as apples, pineapples, bananas, passion fruits, avocados, and horticulture.

Tourism

The sector is one of the leading foreign exchange generators. Rwanda has unique assets, such as Mountain Gorillas, a great variety of bird species and primate species, game reserves, equatorial forest and the most remote source of the Nile. A single tourist visa has been introduced to ease movement of both domestic and foreign tourists in the three EAC countries (Uganda, Kenya, Rwanda). Major international brand hotels have established their operations in Rwanda. Projects available for investors include Kigali cultural village and Kivu Belt projects.

Glass

Rwanda has significant deposits of the main raw materials required for float glass manufacture. There is opportunity to establish a glass container factory that can serve the regional beverage industry with bottles and drinking glasses. Float and architectural glass for building construction is in high demand.

Pharmaceuticals

Rwanda offers generally accessible health insurance schemes, which has stimulated demand for pharmaceutical drugs in Rwanda. There are opportunities to produce generics of brand-name products and to establish public-private partnerships with the government.

Mining

There are opportunities for mining and trade in:

• -tin, tungsten and coltan
• -gemstones. Such as beryl (aquamarine), corundum
• -industrial minerals and rocks, such as silica sands, limestone, talcum, kaolin, vermiculite, -diatomite, clay, gypsum and pozzolan.

There is also an interest in the upgrade of mining technology and the establishment of  ore smelting and processing plants.to smelt ores

Textiles and leather

Currently there is no operational tannery, and all hides and skins are exported as raw material. Opportunities exist in the production of garments for local and export market, whereby materials can be sourced locally or be imported. 

For more information about the legal aspects of investing and doing business in Rwanda:

Jean Pierre Tuyishime
Managing Partner
FixLex Law Chambers
Email: tuyishimelaw@gmail.com

Pieter van Welzen
Senior consultant (financial markets) Africa
CMS South Africa
Email: pieter.vanwelzen@cms-rm.com