Rwanda is moving forward with implementing the VAT regime for non-resident providers of digital services and intangible products. The first important step came after the enactment of Law No. 049/2023 (Law), published in the Gazzette on September 14, 2023.
This Law introduced for the first time provisions for taxing the provision of digital services or the supply of digital products by non-resident digital service providers.(including platforms/e-commerce marketplaces)
However, the initial version of the VAT regime for non-resident digital service providers had “few” “open” to interpretation provisions when it comes to,e.g., taxing rules(between other point) but more than other were lacking the clarity on the implementation route, as well as the adoption of the “secondary” legislation.
The adoption of the Ministerial Order No. 004/26/10/TC(Ministerial Order), published on April 29, 2026, from the preliminary overview, looked “like” the legislative piece that was missing, to “give a push” to the final implementation of the technical infrastructure for the development of the VAT on non-resident digital services in Rwanda.
However, that “still” isn’t the case if we thoroughly review the Ministerial Order and the previously adopted Law. Let’s summarize the current legislative framework and the connected rules and requirements for non-resident digital service providers who have clients in Rwanda.
Rwanda VAT on Digital Services
Registration
Ministerial Order that came into force after being published in the official Gazette became effective on July 29, 2026. (three months after enactment)
The Order states that starting with its effective date, the non-resident digital service providers should follow the “simplified” registration route to be able to charge, collect, and remit Rwanda’s VAT on online services. The Order indicates that there are two available routes for VAT registration on online services:
- Direct Registration via the designated online portal or
- Through service of a domestic tax representative
Currently, the “designated portal” isn’t operative, and as such it isn’t an accessible route for a “simplified registration”, directly or through a representative.
For “now,” it seems that the only plausible solution is direct registration through registering an entity, but that “opens” the door for other types of direct taxation responsibilities.
Withholding Regime
Ministerial Order also indicated the “alternative or supplementary route,” which designated payment service providers as withholding agents for collecting and reporting VAT on non-resident digital service providers, in circumstances when the accountable suppliers haven’t done so.
The Order gave three months from the date of its enactment to responsible tax authorities to develop the IT system that will integrate with the systems of designated payment service providers.
Tax authorities shall issue and maintain a list of digital services providers on whose transactions the payment service providers shall collect and report VAT on these transactions. To avoid double taxation, the registered and non-registered digital service providers should from time to time evaluate the aforementioned list.
Registration Threshold
According to the Ministerial Order, it is still not quite clear whether the domestic threshold applies to non-resident digital service providers or they should start collecting VAT on their supplies from the very first transaction.
B2C and B2B
The current regime indicates that non-resident digital service providers should collect VAT on online services from B2C transactions, while for B2B, additional clarity from tax authorities is needed. One of the principal “consequences” that could arise from the lack of clarity is the possibility of double taxation or no taxation, which will lead to the impossibility of claiming the input tax credit.
What’s Next
Taking into account that the portal is still under development, the accountable non-resident online service providers should evaluate their exposure as soon as possible to prepare to register for VAT as soon as the portal goes live.
The exposure is accruing(as the regulations are already “effective”), so the unregistered providers potentially could “receive” an administrative fine when the “new” system becomes operational.
If you have some questions about VAT rules for non-resident providers of digital services in Rwanda, don’t hesitate to reach out.