AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF RWANDA AND THE GOVERNMENT OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION OF THE PEOPLE'S REPUBLIC OF CHINA FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX EVASION AND AVOIDANCE

Ingingo ya mbere: Kwemeza burundu Article One: Ratification Article premier: Ratification Ingingo ya mbere: Kwemeza burundu Article One: Ratification Article premier: Ratification Amasezerano hagati ya Guverinoma ya Repubulika y’u Rwanda na Guverinoma y’Intara yihariye ya Hong Kong ya Repubulika ya Rubanda y’Ubushinwa yo guca burundu gusoresha kabiri ku byerekeye imisoro ku musaruro n’ikumira ry’inyerezwa ry’umusoro n’iryo kutishyura The Agreement between the Government the the Republic of Rwanda and of Government of the Hong Kong Special Administrative Region of the People’s Republic of China for the elimination of double taxation with respect to taxes on income and the prevention of tax evasion du Rwanda L’Accord entre le Gouvernement de la le République Gouvernement de la région administrative spéciale de Hong Kong de la République Populaire de Chine pour l’élimination de la double imposition en matière d’impôts sur le revenu et la prévention de la fraude et de et Official Gazette n° Special of 01/02/2026 199 umusoro hitwajwe icyuho kiri mu itegeko, i Hong Kong, ku wa 09 yakorewe Ukwakira 2025, ari ku mugereka, yemejwe burundu kandi atangiye gukurikizwa uko yakabaye. and avoidance, done at Hong Kong, on 09 October 2025, in Annex, is ratified and becomes fully effective. l’évasion fiscales, fait à Hong Kong, le 09 octobre 2025, en annexe, est ratifié et sort son plein et entier effet. Article 1 Persons Covered This Agreement shall apply to persons who are residents of one or both of the Contracting Parties. For the purposes of the Agreement, income derived by or through an entity or arrangement that is treated as wholly or partly fiscally transparent under the tax law of either Contracting Party shall be considered to be income of a resident of a Contracting Party but only to the extent that the income is treated, for purposes of taxation by that Contracting Party, as the income of a resident of that Contracting Party. The Agreement shall not affect the taxation, by a Contracting Party, of its residents except with respect to the benefits granted under paragraph 2 of Article 9 and Articles 18, 19, 20, 22, 23, 24 and 26.

Ingingo ya 2: Abayobozi bashinzwe gushyira mu bikorwa iri teka Article 2: Authorities responsible for the implementation of this Order Article 2: Autorités l’exécution du présent arrêté chargées de Ingingo ya 2: Abayobozi bashinzwe gushyira mu bikorwa iri teka Article 2: Authorities responsible for the implementation of this Order Article 2: Autorités l’exécution du présent arrêté chargées de Minisitiri w’Intebe, Minisitiri w’Imari n’Igenamigambi na Minisitiri w’Ububanyi n’Amahanga n’Ubutwererane bashinzwe gushyira mu bikorwa iri teka. the Minister of The Prime Minister, Finance and Economic Planning and the Minister and International Cooperation are entrusted with the implementation of this Order. Foreign Affairs of le Ministre des Le Premier Ministre, Finances et de la Planification Économique et le Ministre des Affaires Étrangères et de la Coopération Internationale sont chargés de l’exécution du présent arrêté. Article 2 Taxes Covered This Agreement shall apply to taxes on income imposed on behalf of a Contracting Party or of its political subdivisions or local authorities, irrespective of the manner in which they are levied. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation. The existing taxes to which the Agreement shall apply are: (a) in the case of the Hong Kong Special Administrative Region, (i) profits tax; (ii) salaries tax; and 2 Official Gazette n° Special of 01/02/2026 86 (iii) property tax; whether or not charged under personal assessment (hereinafter referred to as "Hong Kong Special Administrative Region tax"); (b) in the case of Rwanda, (i) Personal Income Tax; (ii) Corporate Income Tax; (iii) Withholding Tax; (iv) Capital Gain Tax; and (v) Tax on Rent of Immovable Property (hereinafter referred to as "Rwandan tax"). 4. The Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting Parties shall notify each other of any significant changes that have been made in their taxation laws.

Ingingo ya 3: Ingingo y’ururimi Article 3: Language provision Article 3: Disposition linguistique Ingingo ya 3: Ingingo y’ururimi Article 3: Language provision Article 3: Disposition linguistique Iri teka rw’Icyongereza. ryateguwe mu rurimi This Order was drafted in English. Le présent arrêté a été rédigé en anglais. Article 3 General Definitions 1. For the purposes of this Agreement, unless the context otherwise requires: (a) (i) the term "Hong Kong Special Administrative Region" means any place where the tax laws of the Hong Kong Special Administrative Region of the People's Republic of China apply; 3 Official Gazette n° Special of 01/02/2026 87 (ii) the term "Rwanda" means the Republic of Rwanda and when used in geographical sense, includes all the territory, lakes and any other area in the lakes and the air within which Rwanda may exercise sovereign rights or jurisdiction in accordance with international law· ' the term "business" includes the performance of professional services and of other activities of an independent character; the term "company" means any body corporate or any entity that is treated as a body corporate for tax purposes; (b) ( c) ( d) the term "competent authority" means: (i) in the case of the Hong Kong Special Administrative Region, the Commissioner of Inland Revenue or his authorized representative; (ii) in the case of Rwanda, the Minister in charge of Finance or his authorized representative; ( e) the terms "Contracting Party" and "other Contracting Party" mean the Hong Kong Special Administrative Region or Rwanda, as the context reqmres; (f) the term "enterprise" applies to the carrying on of any business; (g) the terms "enterprise of a Contracting Party" and "enterprise of the other Contracting Party" mean respectively an enterprise carried on by a resident of a Contracting Party and an enterprise carried on by a resident of the other Contracting Party; (h) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a Contracting Party, except when the ship or aircraft is operated solely between places in the other Contracting Party; (i) the term "national", in relation to Rwanda, means: (i) any individual possessing the nationality of Rwanda; 4 Official Gazette n° Special of 01/02/2026 88 (ii) any legal person or association deriving its status as such from the laws in force in Rwanda; the term "person" includes an individual, a company, a trust, a partnership and any other body of persons; the term "recognized pension fund" of a Contracting Party means an entity or arrangement established in that Contracting Party that is treated as a separate person under the taxation laws of that Contracting Party and: (i) that is established and operated exclusively or almost exclusively to administer or provide retirement benefits and ancillary or incidental benefits to individuals and that is regulated as such by that Contracting Party or one of its political subdivisions or local authorities; or (ii) that is established and operated exclusively or almost exclusively to invest funds for the benefit of entities or arrangements referred to in subdivision (i). 2. As regards the application of the Agreement at any time by a Contracting Party, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that Contracting Party for the purposes of the taxes to which the Agreement applies, any meaning under the applicable tax laws of that Contracting Party prevailing over a meaning given to the term under other laws of that Contracting Party.

Ingingo ya 4: Gutangira gukurikizwa Article 4: Entry into force Article 4: Entrée en vigueur Official Gazette n° Special of 01/02/2026 197 ITEKA RYA PEREZIDA Nº 004/01 RYO KU WA 27/01/2026 RYEMEZA BURUNDU AMASEZERANO HAGATI YA GUVERINOMA YA REPUBULIKA Y’U RWANDA NA GUVERINOMA Y’INTARA YIHARIYE YA HONG KONG YA RUBANDA REPUBULIKA GUCA Y’UBUSHINWA BURUNDU GUSORESHA KABIRI KU BYEREKEYE KU MUSARURO N’IKUMIRA RY’UMUSORO RY’INYEREZWA N’IRYO KUTISHYURA UMUSORO HITWAJWE ICYUHO KIRI MU ITEGEKO, YAKOREWE I HONG KONG, KU WA 09 UKWAKIRA 2025 IMISORO YO YA AND RWANDA BETWEEN RATIFYING PRESIDENTIAL ORDER Nº 004/01 OF THE 27/01/2026 AGREEMENT THE GOVERNMENT OF THE REPUBLIC THE OF GOVERNMENT OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION OF PEOPLE’S REPUBLIC OF CHINA FOR THE ELIMINATION DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX EVASION AND AVOIDANCE, DONE AT HONG KONG, ON 09 OCTOBER 2025 THE OF DE ENTRE 27/01/2026 ARRÊTÉ PRÉSIDENTIEL N° 004/01 RATIFIANT DU LE L’ACCORD GOUVERNEMENT LA RÉPUBLIQUE DU RWANDA ET LE GOUVERNEMENT DE LA RÉGION ADMINISTRATIVE SPÉCIALE DE HONG KONG DE LA RÉPUBLIQUE POPULAIRE DE CHINE POUR L’ÉLIMINATION DE LA DOUBLE IMPOSITION MATIÈRE D’IMPÔTS SUR LE REVENU ET LA PRÉVENTION DE LA FRAUDE ET DE L’ÉVASION FISCALES, FAIT À HONG KONG, LE 09 OCTOBRE 2025 EN Twebwe, KAGAME Paul, Perezida wa Repubulika; We, KAGAME Paul, President of the Republic; Nous, KAGAME Paul, Président de la République; rya Dushingiye ku Repubulika y’u Rwanda, cyane cyane mu ngingo zaryo, iya 112 n’iya 168; Itegeko Nshinga to the Constitution of the Pursuant Republic of Rwanda, especially in Articles 112 and 168; Vu la Constitution de la République du Rwanda, spécialement en ses articles 112 et 168; Dushingiye ku Itegeko nº 004/2026. ryo ku wa 27/01/2026 ryemera kwemeza burundu Amasezerano hagati ya Guverinoma ya Repubulika y’u Rwanda na Guverinoma y’Intara yihariye ya Hong Kong ya Repubulika ya Rubanda y’Ubushinwa yo guca burundu gusoresha kabiri ku to Law n° 004/2026 of Pursuant 27/01/2026 approving the ratification of the Agreement between the Government of the Republic of Rwanda the Government of the Hong Kong Special Administrative Region of the People’s Republic of China for the elimination of and Vu la Loi n° 004/2026 du 27/01/2026 approuvant la ratification de l’Accord entre le Gouvernement de la République du Rwanda et le Gouvernement de la région administrative spéciale de Hong Kong de la République Populaire de Chine pour l’élimination de la double imposition en Official Gazette n° Special of 01/02/2026 198 byerekeye imisoro ku musaruro n’ikumira ry’inyerezwa ry’umusoro no kutishyura umusoro, yashyiriweho umukono i Hong Kong, ku wa 09 Ukwakira 2025; double taxation with respect to taxes on income and the prevention of tax evasion and avoidance, signed in Hong Kong on 09 October 2025; matière d’impôts sur le revenu et la l’évasion prévention de fiscales, signé à Hong Kong, le 09 octobre 2025; la fraude et ya Repubulika Tumaze kubona Amasezerano hagati ya Guverinoma ya Repubulika y’u Rwanda na Guverinoma y’Intara yihariye ya Hong Kong ya Rubanda y’Ubushinwa yo guca burundu gusoresha kabiri ku byerekeye imisoro ku musaruro n’ikumira ry’inyerezwa ry’umusoro n’iryo kutishyura umusoro hitwajwe icyuho kiri mu itegeko, yakorewe i Hong Kong, ku wa 09 Ukwakira 2025; Considering the Agreement between the Government of the Republic of Rwanda and the Government of the Hong Kong Special Administrative Region of the the for People’s Republic of China elimination of double taxation with respect to taxes on income and the prevention of tax evasion and avoidance, done at Hong Kong, on 09 October 2025; l’Accord le entre Considérant Gouvernement de la République du Rwanda et le Gouvernement de la région administrative spéciale de Hong Kong de la République Populaire de Chine pour l’élimination de la double imposition en matière d’impôts sur le revenu et la prévention de la fraude et de l’évasion fiscales, fait à Hong Kong, le 09 octobre 2025; Bisabwe n’Igenamigambi; na Minisitiri w’Imari On proposal by the Minister of Finance and Economic Planning; Sur proposition du Ministre des Finances et de la Planification Économique; Inama y’Abaminisitiri imaze kubisuzuma no kubyemeza; After consideration and approval by the Cabinet; Après examen et adoption par le Conseil des Ministres; DUTEGETSE: DO ORDER: ARRÊTONS: Ingingo ya 4: Gutangira gukurikizwa Article 4: Entry into force Article 4: Entrée en vigueur Iri teka ritangira gukurikizwa ku munsi ritangarijweho mu Igazeti ya Leta ya Repubulika y’u Rwanda. This Order comes into force on the date of its publication in the Official Gazette of the Republic of Rwanda. Le présent arrêté entre en vigueur le jour de sa publication au Journal Officiel de la République du Rwanda. Official Gazette n° Special of 01/02/2026 200 Kigali, 27/01/2026 (sé) KAGAME Paul Perezida wa Repubulika President of the Republic Président de la République (sé) Dr NSENGIYUMVA Justin Minisitiri w’Intebe Prime Minister Premier Ministre Bibonywe kandi bishyizweho Ikirango cya Repubulika: Seen and sealed with the Seal of the Republic: Vu et scellé du Sceau de la République: (sé) Dr UGIRASHEBUJA Emmanuel Minisitiri w’Ubutabera akaba n’Intumwa Nkuru ya Leta Minister of Justice and Attorney General Ministre de la Justice et Garde des Sceaux Official Gazette n° Special of 01/02/2026 201 AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF RWANDA AND THE GOVERNMENT OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION OF THE PEOPLE'S REPUBLIC OF CHINA FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX EVASION AND AVOIDANCE The Government of the Republic of Rwanda and the Government of the Hong Kong Special Administrative Region of the People's Republic of China, Desiring to further develop their economic relationship and to enhance their co operation in tax matters, Intending to conclude an Agreement for the elimination of double taxation with respect to taxes on income without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this Agreement for the indirect benefit of residents of third jurisdictions), Have agreed as follows: Official Gazette n° Special of 01/02/2026 85 1. 2. 3. 1. 2. Article 4 Resident 1. For the purposes of this Agreement, the term "resident of a Contracting Party" means: (a) in the case of the Hong Kong Special Administrative Region, (i) any individual who ordinarily resides in the Hong Kong Special Administrative Region; Official Gazette n° Special of 01/02/2026 89 (ii) any individual who stays in the Hong Kong Special Administrative Region for more than 180 days during a year of assessment or for more than 300 days in two consecutive years of assessment one of which is the relevant year of assessment; (iii) a company incorporated in the Hong Kong Special Administrative Region or, if incorporated outside the Hong Kong Special Administrative Region, being normally managed or controlled in the Hong Kong Special Administrative Region; (iv) any other person constituted under the laws of the Hong Kong Special Administrative Region or, if constituted outside the Hong Kong Special Administrative Region, being normally managed or controlled in the Hong Kong Special Administrative Region; (b) in the case of Rwanda, any person who, under the laws of Rwanda, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in Rwanda in respect only of income from sources in Rwanda; (c) in the case of either Contracting Party, the Government of that Contracting Party and any political subdivision or local authority thereof as well as a recognized pension fund of that Contracting Party. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting Parties, then his status shall be determined as follows: (a) (b) he shall be deemed to be a resident only of the Contracting Party in which he has a permanent home available to him; if he has a permanent home available to him in both Contracting Parties, he shall be deemed to be a resident only of the Contracting Party with which his personal and economic relations are closer ( centre of vital interests); if the Contracting Party in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either Contracting Party, he shall be deemed to be a resident only of the Contracting Party in which he has an habitual abode; 6 Official Gazette n° Special of 01/02/2026 90 ( c) ( d) if he has an habitual abode in both Contracting Parties or in neither of them, he shall be deemed to be a resident only of the Contracting Party in which he has the right of abode (in the case of the Hong Kong Special Administrative Region) or of which he is a national (in the case of Rwanda); if he has the right of abode in the Hong Kong Special Administrative Region and is also a national of Rwanda, or ifhe does not have the right of abode in the Hong Kong Special Administrative Region nor is he a national of Rwanda, the competent authorities of the Contracting Parties shall settle the question by mutual agreement. 3. Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting Parties, the competent authorities of the Contracting Parties shall endeavour to determine by mutual agreement the Contracting Party of which such person shall be deemed to be a resident for the purposes of the Agreement, having regard to its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors. In the absence of such agreement, such person shall not be entitled to any relief or exemption from tax provided by the Agreement except to the extent and in such manner as may be agreed upon by the competent authorities of the Contracting Parties.

Article 5 Permanent Establishment 1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; Official Gazette n° Special of 01/02/2026 91 (c) an office; ( d) a factory; (e) a workshop; (f) (g) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; and a farm, plantation or other place where agricultural, forestry or related activities are carried on. 3. 4. A building site, a construction, assembly or installation project or supervisory activities in connection with such site or project, constitutes a permanent establishment but only if such site, project or activities continue for a period or periods aggregating more than 183 days in any twelve-month period commencing or ending in the taxable period concerned. For the sole purpose of determining whether the 183-day period referred to in paragraph 3 has been exceeded: (a) where an enterprise of a Contracting Party carries on activities in the other Contracting Party at a place that constitutes a building site or a construction, assembly or installation project, or carries on supervisory activities in connection with such a place, and these activities are carried on during one or more periods of time that, in the aggregate, exceed 30 days without exceeding 183 days; and (b) connected activities are carried on- at ( or, in the case of supervisory activities, in connection with) the same building site or construction, assembly or installation project during different periods of time, each exceeding 30 days, by one or more enterprises closely related to the first­ mentioned enterprise, these different periods of time shall be added to the period of time during which the first-mentioned enterprise has carried on activities at that building site or construction, assembly or installation project. Official Gazette n° Special of 01/02/2026 92 5. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: (a) (b) ( c) ( d) ( e) (f) the use of facilities solely for the purpose of storage or display of goods or merchandise belonging to the enterprise; the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage or display; the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity; the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to ( e ), provided that such activity or, in the case of subparagraph (f), the overall activity of the fixed place of business, is of a preparatory or auxiliary character. 6. Paragraph 5 shall not apply to a fixed place of business that is used or maintained by an enterprise if the same enterprise or a closely related enterprise carries on business activities at the same place or at another place in the same Contracting Party and: (a) (b) that place or other place constitutes a permanent establishment for the enterprise or the closely related enterprise under the provisions of this Article; or the overall activity resulting from the combination of the activities carried on by the two enterprises at the same place, or by the same enterprise or closely related enterprises at the two places, is not of a preparatory or auxiliary character, Official Gazette n° Special of 01/02/2026 93 provided that the business activities carried on by the two enterprises at the same place, or by the same enterprise or closely related enterprises at the two places, constitute complementary functions that are part of a cohesive business operation. 7. Notwithstanding the prov1s10ns of paragraphs 1 and 2 but subject to the provisions of paragraph 8, where a person is acting in a Contracting Party on behalf of an enterprise and, in doing so, habitually concludes contracts, or habitually plays the principal role leading to the conclusion of contracts that are routinely concluded without material modification by the enterprise, and these contracts are: (a) in the name of the enterprise; or (b) for the transfer of the ownership of, or for the granting of the right to use, property owned by that enterprise or that the enterprise has the right to use; or ( c) for the provision of services by that enterprise, that enterprise shall be deemed to have a permanent establishment in that Contracting Party in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 5 which, if exercised through a fixed place of business ( other than a fixed place of business to which paragraph 6 would apply), would not make this fixed place of business a permanent establishment under the provisions of that paragraph. 8. Paragraph 7 shall not apply where the person acting in a Contracting Party on behalf of an enterprise of the other Contracting Party carries on business in the first-mentioned Contracting Party as an independent agent and acts for the enterpri~e in the ordinary course of that business. Where, however, a person acts; ;xclusiv~ly or almost exclusively on behalf of one or more enterprises to which it is•. closely related, that person shall not be considered to be an independent agent within the meaning of this paragraph with respect to any such enterprise. 9. The fact that a company which is a resident of a Contracting Party controls or is controlled by a company which is a resident of the other Contracting Party, or 10 Official Gazette n° Special of 01/02/2026 94 which carries on business in that other Contracting Party ( whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. 10. For the purposes of this Article, a person or enterprise is closely related to an enterprise if, based on all the relevant facts and circumstances, one has control of the other or both are under the control of the same persons or enterprises. In any case, a person or enterprise shall be considered to be closely related to an enterprise if one possesses directly or indirectly more than 50 per cent of the beneficial interest in the other ( or, in the case of a company, more than 50 per cent of the aggregate vote and value of the company's shares or of the beneficial equity interest in the company) or if another person or enterprise possesses directly or indirectly more than 50 per cent of the beneficial interest (or, in the case of a company, more than 50 per cent of the aggregate vote and value of the company's shares or of the beneficial equity interest in the company) in the person and the enterprise or in the two enterprises.

Article 6 Income from Immovable Property 1. 2. Income derived by a resident of a Contracting Party from immovable property (including income from agriculture or forestry) situated in the other Contracting Party may be taxed in that other Contracting Party. The term "immovable property" shall have the meaning which it has under the law of the Contracting Party in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; ships and aircraft shall not be regarded as immovable property. 3. The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovable property. Official Gazette n° Special of 01/02/2026 95 4. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an enterprise. Article 6, situated in that other Contracting Party. However, this paragraph does not apply to gains derived from the alienation of shares: (a) (b) quoted on such stock exchange as may be agreed between the competent authorities of the Contracting Parties; or alienated or exchanged in the framework of a reorganization of a company, a merger, a scission or a similar operation. 5. Gains from the alienation of any property, other than that referred to in paragraphs 1, 2, 3 and 4, shall be taxable only in the Contracting Party of which the alienator is a resident.

Article 7 Business Profits 1. 2. 3. The profits of an enterprise of a Contracting Party shall be taxable only in that Contracting Party unless the enterprise carries on business in the other Contracting Party through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other Contracting Party but only so much of them as is attributable to that permanent establishment. Subject to the provisions of paragraph 3, where an enterprise of a Contracting Party carries on business in the other Contracting Party through a permanent establishment situated therein, there shall in each Contracting Party be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. In the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the business of the permanent establishment, including executive and general administrative expenses so incurred, whether in the Contracting Party in which the permanent establishment is situated or elsewhere. However, no such deduction shall be allowed in respect of amounts, if any, paid ( otherwise than towards reimbursement of actual expenses) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission, for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the permanent establishment. Likewise, no account shall be taken, in the determination of the profits of a permanent establishment, for amounts charged ( otherwise than towards reimbursement of actual expenses), by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents 12 Official Gazette n° Special of 01/02/2026 96 or other rights, or by way of commission for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the head office of the enterprise or any of its other offices. 4. 5. 6. Insofar as it has been customary in a Contracting Party to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting Party from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article. Article 7 shall apply.

Article 8 International Shipping and Air Transport 1. 2. 3. Profits of an enterprise of a Contracting Party from the operation of ships or aircraft in international traffic shall be taxable only in that Contracting Party. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include: 13 Official Gazette n° Special of 01/02/2026 97 (a) (b) profits derived from the rental of ships or aircraft on a bareboat basis where such rental is incidental to the operation of ships or aircraft in international traffic; profits derived from the use or rental of containers used for the transport of goods or merchandise in international traffic where such use or rental is incidental to the operation of ships or aircraft in international traffic.

Article 9 Associated Enterprises 1. Where: (a) (b) an enterprise of a Contracting Party participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting Party; or the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting Party and an enterprise of the other Contracting Party, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. 2. Where a Contracting Party includes in the profits of an enterprise of that Contracting Party - and taxes accordingly - profits on which an enterprise of the other Contracting Party has been charged to tax in that other Contracting Party and the profits so included are profits which would have accrued to the enterprise of the first-mentioned Contracting Party if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then that other Contracting Party shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other 14 Official Gazette n° Special of 01/02/2026 98 provisions of this Agreement and the competent authorities of the Contracting Parties shall if necessary consult each other.

Article 10 Dividends 1. 2. 3. Dividends paid by a company which is a resident of a Contracting Party to a resident of the other Contracting Party may be taxed in that other Contracting Party. However, dividends paid by a company which is a resident of a Contracting Party may also be taxed in that Contracting Party according to the laws of that Contracting Party, but if the beneficial owner of the dividends is a resident of the other Contracting Party, the tax so charged shall not exceed 7.5 per cent of the gross amount of the dividends. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. Notwithstanding the provisions of paragraph 2, dividends arising in a Contracting Party are exempt from tax in that Contracting Party, if they are paid to: (a) in the case of the Hong Kong Special Administrative Region, (i) the Government of the Hong Kong Special Administrative Region; (ii) the Hong Kong Monetary Authority; (iii) the Exchange Fund; (iv) any entity wholly or mainly owned, directly or indirectly, by the Government of the Hong Kong Special Administrative Region as may be agreed from time to time between the competent authorities of the Contracting Parties; (b) in the case of Rwanda, 15 Official Gazette n° Special of 01/02/2026 99 (i) the Government of Rwanda or any political subdivision or local authority thereof; (ii) Rwanda Social Security Board; (iii) Agaciro Development Fund; (iv) National Bank of Rwanda; (v) Rwanda National Investment Trust Ltd; (vi) Development Bank of Rwanda; (vii) any entity wholly or mainly owned, directly or indirectly, by the Government of Rwanda or any political subdivision or local authority thereof, as may be agreed from time to time between the competent authorities of the Contracting Parties. 4. 5. The term "dividends" as used in this Article means income from shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting Party of which the company making the distribution is a resident. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting Party, carries on business in the other Contracting Party of which the company paying the dividends is a resident through a permanent establishment situated therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case, the provisions of Article 7 shall apply. 6. Where a company which is a resident of a Contracting Party derives profits or income from the other Contracting Party, that other Contracting Party may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other Contracting Party or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment situated in that other Contracting Party, nor subject the company's undistributed profits to a tax on the company's undistributed 16 Official Gazette n° Special of 01/02/2026 100 profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting Party.

Article 11 Interest 1. 2. Interest ansmg in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Contracting Party. However, interest arising in a Contracting Party may also be taxed in that Contracting Party according to the laws of that Contracting Party, but if the beneficial owner of the interest is a resident of the other Contracting Party, the tax so charged shall not exceed 8 per cent of the gross amount of the interest. 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting Party is exempt from tax in that Contracting Party, if it is paid to: (a) in the case of the Hong Kong Special Administrative Region, (i) the Government of the Hong Kong Special Administrative Region; (ii) the Hong Kong Monetary Authority; (iii) the Exchange Fund; (iv) any entity wholly or mainly owned, directly or indirectly, by the Government of the Hong Kong Special Administrative Region as may be agreed from time to time between the competent authorities of the Contracting Parties; (b) in the case of Rwanda, (i) the Government of Rwanda or any political subdivision or local authority thereof; (ii) Rwanda Social Security Board; 17 Official Gazette n° Special of 01/02/2026 101 (iii) Agaciro Development Fund; (iv) National Bank of Rwanda; (v) Rwanda National Investment Trust Ltd; (vi) Development Bank of Rwanda; (vii) any entity wholly or mainly owned, directly or indirectly, by the Government of Rwanda or any political subdivision or local authority thereof, as may be agreed from time to time between the competent authorities of the Contracting Parties. 4. 5. 6. The term "interest" as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures. Penalty charges for late payment shall not be regarded as interest for the purpose of this Article. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the interest arises through a permanent establishment situated therein and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment. In such case, the provisions of Article 7 shall apply. Interest shall be deemed to arise in a Contracting Party when the payer is a resident of that Contracting Party. Where, however, the person paying the interest, whether he is a resident of a Contracting Party or not, has in a Contracting Party a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the Contracting Party in which the permanent establishment is situated. 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount 18 Official Gazette n° Special of 01/02/2026 102 which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting Party, due regard being had to the other provisions of this Agreement.

Article 12 Royalties 1. 2. 3. 4. 5. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Contracting Party. However, royalties arising in a Contracting Party may also be taxed in that Contracting Party according to the laws of that Contracting Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 9 per cent of the gross amount of the royalties. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise through a permanent establishment situated therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such case, the provisions of Article 7 shall apply. Royalties shall be deemed to arise in a Contracting Party when the payer is a resident of that Contracting Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting Party a permanent establishment in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such 19 Official Gazette n° Special of 01/02/2026 103 permanent establishment, then such royalties shall be deemed to arise in the Contracting Party in which the permanent establishment is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting Party, due regard being had to the other provisions of this Agreement.

Article 13 Fees for Technical Services 1. 2. 3. Fees for technical services arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Contracting Party. However, subject to the provisions of Articles 8, 16 and 17, fees for technical services arising in a Contracting Party may also be taxed in that Contracting Party according to the laws of that Contracting Party, but if the beneficial owner of the fees is a resident of the other Contracting Party, the tax so charged shall not exceed 10 per cent of the gross amount of the fees. The term "fees for technical services" as used in this Article means any payment in consideration for any service of a managerial, technical or consultancy nature, unless the payment is made: (a) to an employee of the person making the payment; (b) for teaching in an educational institution or for teaching by an educational institution; or ( c) by an individual for services for the personal use of an individual. 20 Official Gazette n° Special of 01/02/2026 104 4. 5. 6. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the fees for technical services arise through a permanent establishment situated therein and the fees technical services are effectively connected with such permanent for establishment. In such case, the provisions of Article 7 shall apply. For the purposes of this Article, subject to paragraph 6, fees for technical services shall be deemed to arise in a Contracting Party if the payer is a resident of that Contracting Party or if the person paying the fees, whether that person is a resident of a Contracting Party or not, has in a Contracting Party a permanent establishment in connection with which the obligation to pay the fees was incurred, and such fees are borne by the permanent establishment. For the purposes of this Article, fees for technical services shall be deemed not to arise in a Contracting Party if the payer is a resident of that Contracting Party and carries on business in the other Contracting Party through a permanent establishment situated therein and such fees are borne by that permanent establishment. 7. Where, by reason of a special relationship between the payer and the beneficial owner of the fees for technical services or between both of them and some other person, the amount of the fees for technical services, having regard to the services for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting Party, due regard being had to the other provisions of this Agreement.

Article 14 Capital Gains 1. Gains derived by a resident of a Contracting Party from the alienation of immovable property referred to in Article 6 and situated in the other Contracting Party may be taxed in that other Contracting Party. 21 Official Gazette n° Special of 01/02/2026 105 2. 3. 4. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting Party has in the other Contracting Party, including such gains from the alienation of such a permanent establishment ( alone or with the whole enterprise), may be taxed in that other Contracting Party. Gains that an enterprise of a Contracting Party that operates ships or aircraft in international traffic derives from the alienation of such ships or aircraft, or of movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that Contracting Party. Gains derived by a resident of a Contracting Party from the alienation of shares or comparable interests, such as interests in a partnership or trust, may be taxed in the other Contracting Party if, at any time during the 365 days preceding the alienation, these shares or comparable interests derived more than 50 per cent of their value directly or indirectly from immovable property, as defined in

Article 15 Income from Employment 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting Party in respect of an employment shall be taxable only in that Contracting Party unless the employment is exercised in the other Contracting Party. If the employment is 22 Official Gazette n° Special of 01/02/2026 106 so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting Party. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting Party in respect of an employment exercised in the other Contracting Party shall be taxable only in the first-mentioned Contracting Party if: (a) (b) ( c) the recipient is present in the other Contracting Party for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the taxable period concerned; and the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting Party; and the remuneration is not borne by a permanent establishment which the employer has in the other Contracting Party. 3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of a Contracting Party in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of the other Contracting Party shall be taxable only in that other Contracting Party.

Article 16 Directors' Fees Directors' fees and other similar payments derived by a resident of a Contracting Party in his capacity as a member of the board of directors of a company which is a resident of the other Contracting Party may be taxed in that other Contracting Party.

Article 17 Entertainers and Sportspersons 1. Notwithstanding the provisions of Article 15, income derived by a resident of a Contracting Party as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson, from that resident's 23 Official Gazette n° Special of 01/02/2026 107 personal activities as such exercised in the other Contracting Party, may be taxed in that other Contracting Party. 2. Where income in respect of personal activities exercised by an entertainer or a sportsperson acting as such accrues not to the entertainer or sportsperson but to another person, that income may, notwithstanding the provisions of Article 15, be taxed in the Contracting Party in which the activities of the entertainer or sportsperson are exercised. 3. The provisions of paragraphs 1 and 2 shall not apply to income derived from activities performed in a Contracting Party by an entertainer or a sportsperson if his visit to that Contracting Party is wholly or mainly supported by public funds of one or both of the Contracting Parties or political subdivisions or local authorities thereof or if the activities are exercised within the framework of a cultural or sports exchange programme approved by both Contracting Parties. In such case, the income is taxable only in the Contracting Party of which the entertainer or sportsperson is a resident.

Article 18 Pensions Pensions and other similar remuneration arising in a Contracting Party and paid to a resident of the other Contracting Party in consideration of past employment or self employment shall be taxable only in the first-mentioned Contracting Party.

Article 19 Government Service 1. (a) Salaries, wages and other similar remuneration, other than a pension, paid by the Government of a Contracting Party or a political subdivision or a local authority thereof to an individual in respect of services rendered to that Contracting Party or subdivision or authority shall be taxable only in that Contracting Party. (b) However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting Party if the services are rendered in 24 Official Gazette n° Special of 01/02/2026 108 that other Contracting Party and the individual is a resident of that other Contracting Party who: (i) in the case of the Hong Kong Special Administrative Region, has the right of abode therein and in the case of Rwanda, is a national thereof; or (ii) did not become a resident of that other Contracting Party solely for the purpose of rendering the services. 2. The provisions of Articles 15, 16 and 17 shall apply to salaries, wages and other similar remuneration in respect of services rendered in connection with a business carried on by the Government of a Contracting Party or a political subdivision or a local authority thereof.

Article 20 Students Payments which a student who is or was immediately before visiting a Contracting Party a resident of the other Contracting Party, and who is present in the first mentioned Contracting Party solely for the purpose of his education, receives for the purpose of his maintenance or education shall not be taxed in that Contracting Party, provided that such payments arise from sources outside that Contracting Party.

Article 21 Other Income I. 2. Items of income of a resident of a Contracting Party, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that Contracting Party. The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting Party, carries on business in the other Contracting Party through a permanent establishment situated therein and the right or property in respect of which the income is paid is effectively 25 Official Gazette n° Special of 01/02/2026 109 connected with such permanent establishment. In such case, the provisions of

Article 22 Elimination of Double Taxation 1. Double taxation shall be eliminated as follows: (a) in the case of the Hong Kong Special Administrative Region, subject to the provisions of the laws of the Hong Kong Special Administrative Region relating to the allowance of a credit against Hong Kong Special Administrative Region tax of tax paid in a jurisdiction outside the Hong Kong Special Administrative Region (which shall not affect the general principle of this Article), Rwandan tax paid under the laws of Rwanda and in accordance with the provisions of this Agreement ( except to the extent that these provisions allow taxation by Rwanda solely because the income is also income derived by a resident of Rwanda), whether directly or by deduction, in respect of income derived by a person who is a resident of the Hong Kong Special Administrative Region from sources in Rwanda, shall be allowed as a credit against Hong Kong Special Administrative Region tax payable in respect of that income, provided that the credit so allowed does not exceed the amount of Hong Kong Special Administrative Region tax computed in respect of that income in accordance with the tax laws of the Hong Kong Special Administrative Region. (b) in the case of Rwanda, tax paid by a resident of Rwanda in respect of income taxable in the Hong Kong Special Administrative Region, in accordance with the provisions of the Agreement, shall be deducted from taxes due in accordance with the laws of Rwanda (which shall not affect the general principle hereof). Such deduction shall not, however, exceed the tax payable in Rwanda that 26 Official Gazette n° Special of 01/02/2026 110 2. 1. 2. would otherwise be payable on the income taxable in the Hong Kong Special Administrative Region. For the purposes of paragraph 1, tax paid in a Contracting Party shall be deemed to include the amount of tax which would have been paid in that Contracting Party if tax exemption or reduction had not been granted in accordance with the internal laws providing for incentives which are designed to promote economic development in that Contracting Party. The provisions of this paragraph shall be effective for a period of 5 years starting from the entry into force of the Agreement. However, the period may be extended by mutual agreement of the competent authorities of the Contracting Parties.

Article 23 Non-Discrimination Persons who, in the case of the Hong Kong Special Administrative Region, have the right of abode or are incorporated or otherwise constituted therein, and, in the case of Rwanda, are Rwandan nationals, shall not be subjected in the other Contracting Party to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which persons who have the right of abode or are incorporated or otherwise constituted in that other Contracting Party ( where that other Contracting Party is the Hong Kong Special Administrative Region) or nationals of that other Contracting Party (where that other Contracting Party is Rwanda) in the same circumstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting Parties. The taxation on a permanent establishment which an enterprise of a Contracting Party has in the other Contracting Party shall not be less favourably levied in that other Contracting Party than the taxation levied on enterprises of that other Contracting Party carrying on the same activities. This provision shall not be construed as obliging a Contracting Party to grant to residents of the other Contracting Party any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. 27 Official Gazette n° Special of 01/02/2026 111 3. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, paragraph 6 of Article 12 or paragraph 7 of Article 13 apply, interest, royalties, fees for technical services and other disbursements paid by an enterprise of a Contracting Party to a resident of the other Contracting Party shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned Contracting Party. Enterprises of a Contracting Party, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting Party, shall not be subjected in the first-mentioned Contracting Party to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned Contracting Party are or may be subjected.

Article 24 Mutual Agreement Procedure 1. Where a person considers that the actions of one or both of the Contracting Parties result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the internal laws of those Contracting Parties, present his case to the competent authority of either Contracting Party. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting Party, with a view to the avoidance of taxation which is not in accordance with the Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the internal laws of the Contracting Parties. 3. The competent authorities of the Contracting Parties shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or 28 Official Gazette n° Special of 01/02/2026 112 application of the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting Parties may communicate with each other directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs.

Article 25 Exchange of Information 1. 2. The competent authorities of the Contracting Parties shall exchange such information as is foreseeably relevant for carrying out the provisions of this Agreement or to the administration or enforcement of the internal laws of the Contracting Parties concerning taxes covered by the Agreement, insofar as the taxation thereunder is not contrary to the Agreement. The exchange of information is not restricted by Article 1. Any information received under paragraph 1 by a Contracting Party shall be treated as secret in the same manner as information obtained under the internal laws of that Contracting Party and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. Notwithstanding the foregoing, information received by a Contracting Party may be used for other purposes when such information may be used for such other purposes under the laws of both Contracting Parties and the competent authority of the supplying Contracting Party authorizes such use. Information received shall not be disclosed to any third jurisdiction for any purpose. 29 Official Gazette n° Special of 01/02/2026 113 3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting Party the obligation: (a) (b) ( c) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting Party; to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting Party; to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information the disclosure of which would be contrary to public policy ( ordre public). 4. 5. If information is requested by a Contracting Party in accordance with this Article, the other Contracting Party shall use its information gathering measures to obtain the requested information, even though that other Contracting Party may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3 but in no case shall such limitations be construed to permit a Contracting Party to decline to supply information solely because there is no tax interest in such information to that Contracting Party. In no case shall the prov1s10ns of paragraph 3 be construed to permit a Contracting Party to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person.

Article 26 Members of Government Missions Nothing in this Agreement shall affect the fiscal privileges of members of government missions, including consular posts, under the general rules of international law or under the provisions of special agreements. 30 Official Gazette n° Special of 01/02/2026 114

Article 27 Entitlement to Benefits 1. Notwithstanding the other provisions of this Agreement, a benefit under the Agreement shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the Agreement. 2. Nothing in the Agreement shall prejudice the right of each Contracting Party to apply its internal laws and measures concerning tax evasion or avoidance, whether or not described as such.

Article 28 Entry into Force 1. Each of the Contracting Parties shall notify the other in writing, through official channels, of the completion of the procedures required by its law for the bringing into force of this Agreement. The Agreement shall enter into force on the date of the later of these notifications. 2. The provisions of the Agreement shall thereupon have effect: (a) in the Hong Kong Special Administrative Region, in respect of Hong Kong Special Administrative Region tax, for any year of assessment beginning on or after the first day of April in the calendar year next following that in which the Agreement enters into force; (b) in Rwanda, (i) in respect of taxes withheld at source, on amounts paid or credited on or after the first day of January in the calendar year next following that in which the Agreement enters into force; 31 Official Gazette n° Special of 01/02/2026 115 (ii) in respect of other taxes, on income derived in any taxable year beginning on or after the first day of January in the calendar year next following that in which the Agreement enters into force.

Article 29 Termination This Agreement shall remain in force until terminated by a Contracting Party. Either Contracting Party may terminate the Agreement by giving the other Contracting Party written notice of termination, through official channels, at least six months before the end of any calendar year after the expiration of a period of five years from the date of entry into force of the Agreement. In such event, the Agreement shall cease to have effect: (a) in the Hong Kong Special Administrative Region, in respect of Hong Kong Special Administrative Region tax, for any year of assessment beginning on or after the first day of April in the calendar year next following that in which the notice of termination is given; (b) in Rwanda, (i) (ii) in respect of taxes withheld at source, on amounts paid or credited on or after the first day of January in the calendar year next following that in which the notice of termination is given; in respect of other taxes, on income derived in any taxable year beginning on or after the first day of January in the calendar year next following that in which the notice of termination is given. 32 Official Gazette n° Special of 01/02/2026 116 IN WITNESS WHEREOF, the undersigned, being duly authorized thereto, have signed this Agreement. DONE in duplicate at Hong Kong this 9th day of October 2025, in the English language. For the Government of the Republic of Rwanda For the Government of the Hong Kong Special Administrative Region of the People's Republic of China Yusuf Murangwa Minister of Finance and Economic Planning Christopher Hui / / Secretary for Financial Services and the Treasury 33 Official Gazette n° Special of 01/02/2026 117 PROTOCOL TO THE AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF RWANDA AND THE GOVERNMENT OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION OF THE PEOPLE'S REPUBLIC OF CHINA FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX EVASION AND AVOIDANCE At the time of signing the Agreement between the Government of the Republic of Rwanda and the Government of the Hong Kong Special Administrative Region of the People's Republic of China for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (hereinafter referred to as the "Agreement"), the two Governments have agreed upon the following provisions which shall form an integral part of the Agreement. 1. With reference to paragraph 2 of Article 22 (Elimination of Double Taxation) of the Agreement It is understood that the competent authorities of the Contracting Parties shall notify each other of and provide clarifications on the incentives that fall within the scope of this paragraph. 2. With reference to Article 25 (Exchange of Information) of the Agreement It is understood that in addition to the taxes covered by the Agreement, the provisions of Article 25 of the Agreement also apply to the following taxes that are administrated and enforced in Rwanda: (a) Value Added Tax; (b) Excise Duty; ( c) Tax on Minerals; and (d) Gaming Tax. 34 Official Gazette n° Special of 01/02/2026 118 3. With reference to Article 26 (Members of Government Missions) of the Agreement It is understood that the term "government missions", in the case of Rwanda, means diplomatic missions. IN WITNESS WHEREOF, the undersigned, being duly authorized thereto, have signed this Protoco 1. DONE in duplicate at Hong Kong this 9th day of October 2025, in the English language. For the Government of the Republic of Rwanda For the Government of the Hong Kong Special Administrative Region of the People's Republic of China Yusuf Murangwa Minister of Finance and Economic Planning Christopher Hui Secretary for Financial Services and the Treasury Official Gazette n° Special of 01/02/2026 119