Rwanda enacts Law n° 056/2024 establishing tax on minerals, restructuring royalty and export-tax rates to incentivise value-addition over raw-mineral exports

Mechanism

Law n° 056/2024 is Rwanda's principal fiscal statute governing mineral taxation. It operates under MINECOFIN tax-policy authority (collected by the Rwanda Revenue Authority) and is structurally distinct from the licensing/regulatory Mining Law n° 072/2024 enacted the same day under the Ministry of Natural Resources / RMB authority. The statute replaces the 2013 minerals-tax law and resets both the rate schedule and the category structure.

Key changes:

• Six-category schedule. Replaces the prior three-category framework

with six explicit mineral classes: base metals, gemstones, platinum group metals, rare earth elements, energy minerals, and gold. Each has its own rate for domestically processed output (royalty) and for raw-mineral exports.

• Differential processed vs. raw rates. The statute encodes a

value-addition incentive directly into the tax schedule by setting different rates for processed and unprocessed minerals (royalty rates apply to domestically processed sales; export tax applies to raw exports). Indicative rates from MINECOFIN/RRA guidance: - Base metals — 3% royalty (down from 4%) / 2% raw export - Gemstones — 2% royalty / 3% raw export - Platinum group metals — 2% / 2% - Rare earth elements — 2% / 1% - Energy minerals — 3% / 2% - Gold — 0.5% royalty (down from 6%) / 0.5% raw export

• Steep gold royalty cut. The headline change is the gold royalty

collapsing from 6% to 0.5%, reflecting the government's view that the prior rate had driven gold flows informal/cross-border and out of the taxed channel — the cut aims to bring artisanal and small-scale gold output back into the formal RRA tax base.

• Withholding obligations. The law imposes withholding duties on

local mineral processors and exporters, who must remit the tax at point of sale or export rather than relying on producer self-assessment.

• NST1 alignment. MINECOFIN explicitly frames the rate restructure

as supporting the value-addition pillar of the National Strategy for Transformation (NST1) — i.e., raising the share of mineral revenue retained domestically through processing, refining and smelting.

Downstream implications

• Pairs with Law n° 072/2024 (the licensing/regulatory statute) to give

Rwanda a fully reset 2024 mining-policy stack: regulatory authority + fiscal instrument operating in tandem.

• The processed-vs-raw differential is a softer, price-signal version

of the outright raw-export bans seen in Indonesia, Zimbabwe and Tanzania — it nudges rather than mandates value-addition, which preserves trade-flow continuity while shifting margin domestically.

• Gold royalty cut from 6% to 0.5% is a deliberate formalisation play

aimed at the artisanal-and-small-scale (ASM) channel; revenue impact is mixed (lower rate but potentially wider base if informal flows formalise).

• Rare-earth rate setting (2% royalty / 1% raw export) is a forward

positioning move — Rwanda has no current rare-earth production at scale but the law sets the fiscal framework ahead of any future REE projects.

• For 3T processing economics: base-metal royalty cut from 4% → 3%

improves the margin profile of Rwandan smelters processing tin, tantalum and tungsten concentrates (including cross-border DRC feedstock), reinforcing Rwanda's position as the principal African 3T processing hub.

Open questions

• Implementing ministerial orders specifying the precise tariff

classification rules (HS-code mapping per mineral category) and the withholding-mechanism procedure — are these in force?

• Interaction with the East African Community common external tariff

on minerals and with bilateral DRC concentrate-import arrangements.

• Whether the gold royalty cut is achieving the formalisation outcome

(post-2024 RRA gold tax-base data not yet public).

• Treatment of cross-border DRC 3T concentrate under the new export-tax

category (is it raw-export-taxed on re-export, or treated as processed once it passes through a Rwandan smelter?).