On the days 25-31 July 2015, the Policy Research Center contracted by ICTD (International Center for Tax and Development) have carried out training and workshop for Rwandan Revenue Authority in Kigali, Rwanda, dedicated to international taxation and transfer pricing.

The beneficiaries of the training were 2 separate groups. One composed of approximately 20 tax policy and tax administration specialists, as well as specialists from other sectors, who may potentially become future trainers of the similar training. The second group was composed of about 70 field tax inspectors, who obtained opportunity to develop their understanding of international taxation and transfer pricing with reference to practical scenarios.

 The training for the first groups was designed in a way to allow for proper understanding of all the relevant concepts of international taxation and transfer pricing, as well as their relevance to Rwanda. The participants had also the opportunity to discuss with the trainers the double tax treaties of Rwanda and identify the respective weaknesses, which may have potential negative impact on the revenue collection of Rwanda, and also domestic law provisions, which contained definition of income from sources and the tax collection mechanisms, where also weaknesses and opportunities were identified. The participants could discuss jointly with the trainers the ideas and suggestions for improvements of both – double tax treaties of Rwanda and domestic law provisions. The training was composed of the following sections:

• Introduction to International Taxation and practical applications 
• Double taxation
• Elimination of Double Taxation and Introduction to Tax Treaties   
• Structure of Tax Treaties 
• Comparison between OECD and UN Model Tax Conventions 
• Special Rules protecting Tax Base of Developing Countries 
• Practical Application of Tax Treaties on Case Studies  
• Double Taxation and Double Non-Taxation 
• Tax Planning, Tax Avoidance and Tax Evasion 
• Anti-avoidance provisions and protection of tax base 
• Extractive Industry and international taxation  
• Introduction to Transfer Pricing 
• Legal Framework and Tax Treaties provisions related to Transfer Pricing 
• Determination of Arm’s Length Price 
• Methods  
• Intra-group services 
• Transfer Pricing Documentation 
• Double Taxation due to Transfer Pricing and Dispute Settlement  

The second group had a shorter time available in comparison to the first group (2 vs. 5 training days), and therefore the training could not allow for in depth analysis of the relevant concepts, but the key international tax and transfer pricing principles were explained and also applied on practical scenarios. The training was composed of the following sections:

• Introduction to International Taxation and relevance to tax audit  
• Residence aspects of International taxation for Rwanda 
• Source aspects of International Taxation for Rwanda 
• Introduction to tax treaties 
• Tax treaty network of Rwanda 
• Abuse of tax treaties 
• Introduction to transfer pricing 
• Introduction to audit strategy 

The participants shared very positive feedback about the training and trainers.  References are available upon request.