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ARTICLE · 29 SEPTEMBER 2025

Secondary Tax Implications Of Transfer Pricing Adjustments: An Extra Layer Of Complexity

In December 2024, during a panel session focused on tax policy and its role in enabling development financing and domestic revenue mobilisation in Africa...

RwandaTax

In December 2024, during a panel session focused on tax policy and its role in enabling development financing and domestic revenue mobilisation in Africa, held as part of the Annual Meetings of the Africa Tax Administration Forum ("ATAF"), Ronald Niwenshuti, the Commissioner General of Rwanda Revenue Authority ("RRA"), acknowledged the support RRA has received from ATAF in the area of international taxation, including transfer pricing. He noted that, thanks to enhanced skills in these areas, revenue collected from international tax audits, including transfer pricing, now accounts for more than 30% of the total tax collections generated through audits.

This suggests that the Rwandan tax administration is becoming increasingly sophisticated in matters of international taxation, particularly in the area of transfer pricing. There is also growing scrutiny of cross-border transactions, especially those involving entities within the same multinational enterprise ("MNE")

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