Rwanda: no tax treaty listed in the BOFiP (Official Bulletin of Public Finances), what this means for your rental income and dividends

No tax treaty with Rwanda is listed in the BOFiP (French Official Tax Bulletin) of treaties in force as of January 1, 2026 (version of April 29, 2026). The income tax guide states: "In the absence of a tax treaty, income is taxable in France." According to the RRA (Rwanda Revenue Authority) guide, Rwanda taxes rent in brackets of 0, 20, and 30. The RRA also indicates a withholding tax of 15 on dividends, excluding dividends between resident companies; its page does not specify the case of a non-resident. Rwanda also has an entry in the French table of states bound to France by an administrative assistance agreement. This page describes these rules and what it cannot say.

Not listed in the conventions, but present in the support table

The BOFiP publishes the annex BOI-ANNX-000306: it lists the tax treaties of France in force on January 1, 2026, in its version of April 29, 2026. Rwanda is not included.

Another government document contains a line item for "Rwanda." The annex to the 2027 draft budget law, concerning France's information exchange network, includes a table of states that have concluded an administrative assistance agreement with France in force as of September 1, 2026. The "Rwanda" line is marked with a single cross. The table has three columns: information exchange agreement or convention conforming to the OECD models (Article 26 of 2005 or the 2002 agreement), agreement with an exchange clause predating Article 26, and amended multilateral tax administrative assistance agreement. The excerpt provided does not indicate in which column the cross is located. Therefore, the page does not specify the nature of the instrument, nor does it attribute any effect to the allocation of tax revenue.

Rwanda is not included on the list of non-cooperative states and territories reproduced in this annex. According to the annex, this list includes 11 states as of the decree of April 15, 2026, which we have not read. It remains valid as of the date of your decision.

Rwandan income of a French tax resident

Tax residence is determined according to Article 4 B of the French General Tax Code (CGI): home or principal place of residence, professional activity, and center of economic interests. Only one criterion is required. A person domiciled in France is taxed on their income from French or foreign sources.

Regarding foreign-source income, the 2026 income tax guide states: "In the absence of a tax treaty, the income is taxable in France," without eliminating the possibility of double taxation. The instructions for form 2047 (for 2025 income) specify, for securities, that income from a country without a treaty must be declared net of foreign tax. Applied to a Rwandan dividend, this rule would lead to declaring the amount net of Rwandan withholding tax: this is our interpretation, which should be verified.

Regarding rental income, the instructions only state that foreign-source rental income must be declared on form 2044 and added to other rental income. The sections I read make no mention of a tax credit on Rwandan rental income. The document does not address this point.

What Rwanda collects

The Rwandan tax administration is the Rwanda Revenue Authority (RRA).

For rental income, the RRA first deducts 50 % from the gross rent for maintenance. Taxpayers can also deduct, with supporting documentation, bank interest on a loan taken out to build or purchase the property. The brochure dates from 2024 and does not distinguish between residents and non-residents. The RRA's dividend page also makes no distinction between them, except for dividends between resident companies.

Rent in Kigali for a French resident: a numerical example (fictitious profile)

Situation. Marc, a fictitious profile, is a tax resident of France. He rents an apartment in Rwanda for a gross annual rent of 6,000,000 FRW (assumed amount).

Issue. He wants to know what taxes Rwanda levies and whether taxes paid there are deductible in France.

Strategy. He applies the RRA scale: a 50% deduction for maintenance, then increments of 0%, 20%, and 30%. He notes that no agreement is listed, therefore no tax credit agreement is read.

Result. The taxable base is 3,000,000 FRW. Rwandan tax is 164,000 FRW on the 20% tax bracket and 600,000 FRW on the 30% tax bracket, totaling 764,000 FRW, or 12.7% of the gross rent. With no loan interest to deduct, no further reduction is applied. In France, this rent remains taxable: French tax depends on the tax brackets and Marc's individual circumstances, and is not calculated here.

Dual residency: two texts, only one rule missing

Under Rwandan law, an individual is considered a resident if they meet one of several conditions: permanent residence in Rwanda, habitual residence, being a Rwandan representing Rwanda abroad, 183 days or more of presence in the country during the tax year, or an average presence of more than 122 days in each of the two preceding periods. A resident is liable for tax on their income from all sources. A non-resident is liable for tax on income originating in Rwanda.

The BOFiP (Official Bulletin of Public Finances) describes the order of priority for determining dual residency as stipulated by tax treaties: permanent residence, closest personal and economic ties, habitual residence, and nationality. It does not address the absence of a tax treaty. Therefore, a person who meets both Article 4 B and Article 4 of Rwandan law has no tie-breaking provision in the texts consulted. The information provided does not offer a solution: the case must be assessed on a case-by-case basis.

French income of a resident of Rwanda

A non-resident is taxed only on their French-source income, subject to tax treaties. The minimum rate is 20% of income up to €29,579 and 30% of income above that amount, for income received in 2025. Dividends from French sources paid to an individual are generally subject to a withholding tax of 12.80% as of January 1, 2026, subject to more favorable treaty provisions; the tax authorities' website specifies 75% for non-cooperative states and territories. The rate applicable to corporations is not listed. As no treaties are listed, no treaty reductions are provided here.

Accounts opened in Rwanda: the annual declaration

Any account, assurance-vie policy, or digital asset opened, used, or closed abroad must be declared annually using form 3916 or 3916-bis. The penalty is €1,500 per undeclared account. The tax authorities' website increases this penalty to €10,000 for an account located in a country without a tax treaty. Rwanda's relevance to this case is not established here.

What changes depending on your situation

• Your tax residence on each date of collection: France, Rwanda, or both.
• The nature of the income: dividend, rent, capital gain, interest.
• The status of the beneficiary: natural person or company.
• The amount withheld at source and its date.
• Accounts or contracts held in Rwanda must be declared in France.

The rule depends on your situation. No results are guaranteed.

What this page does not cover

It does not provide the Rwandan income tax rates, which are covered on our page about life in Rwanda, nor does it address withholdings on interest and royalties, which we were unable to review. It also does not cover inheritance, social security, visas, or residency permits. Local tax matters should be verified with a professional based in Rwanda. French tax matters are covered in our pages on tax residency, tax return 2047, and form 3916.