AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF RWANDA AND THE GOVERNMENT OF THE REPUBLIC OF ANGOLA FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX AVOIDANCE AND EVASION, SIGNED IN KIGALI, RWANDA, ON 15 APRIL 2022

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 ya Repubulika ya Angola yo guca burundu gusoresha kabiri ku byerekeye imisoro ku musaruro n’ikumira ryo kutishyura umusoro yashyiriweho ry’umusoro, n’inyerezwa umukono i Kigali mu Rwanda, ku wa 15 Mata 2022, ari ku mugereka w’iri teka, yemejwe The Agreement between the Government of the Republic of Rwanda and the Government of the Republic of Angola for the elimination of double taxation with respect to taxes on income and the prevention of tax avoidance and evasion, signed in Kigali, Rwanda, on 15 April 2022, annexed to this Order, is ratified and becomes fully effective. le Gouvernement de L’Accord entre la République du Rwanda et le Gouvernement de la République d’Angola pour l’élimination de la double imposition en matière d’impôts sur le revenu et la prévention de la fraude et l’évasion fiscale, signé à Kigali, au Rwanda, le 15 avril 2022, annexé au présent arrêté, est ratifié et sort son plein et entier effet. Official Gazette n° Special of 22/07/2022105 burundu kandi atangiye gukurikizwa uko yakabaye. Article 1 Persons covered 1. This Agreement shall apply to persons who are residents of one or both of the Contracting States. 2. For the purposes of this 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 State shall be considered to be income of a resident of a Contracting State but only to the extent that the income is treated, for purposes of taxation by that State, as the income of a resident ofthat State.

Ingingo ya 2: Abashinzwe gushyira mu bikorwa iri teka Article 2: Authorities responsible for the implementation of this Order Article l’exécution du présent arrêté 2 : Autorités chargées de Ingingo ya 2: Abashinzwe gushyira mu bikorwa iri teka Article 2: Authorities responsible for the implementation of this Order Article 2 : Autorités chargées de l’exécution du présent arrêté Minisitiri w’Intebe, Minisitiri w’Imari n’Igenamigambi na Minisitiri w’Ububanyi n’Amahanga n’Ubutwererane bashinzwe gushyira mu bikorwa iri teka. The Prime Minister, the Minister of Finance and Economic Planning, and the Minister of Foreign Affairs and International Cooperation are entrusted with the implementation of this Order. Le Premier Ministre, le Ministre des 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 1, This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective ofthe manner in which they are levied. 2, 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 as well as taxes on the total amounts of wages or salaries paid by enterprises. 3, The existing taxes to which the Agreement shall apply are: 2 Official Gazette n° Special of 22/07/2022110 (a) in Rwanda: (D (iD (iiD (iv) Iv] Personal Income Tax; Corporate Income Tax; The Withholding Taxes; Capital gain tax; and Tax on Rent of Immovable Property. (hereinafter referred to as "Rwandan tax"); (b) in Angola: (t) ( lt) (il) (t\0 Personal income tax "lmposto sobre os Rendimentos do Trabalho"; Corporate income tax "lmposto Industrial"; Tax on income of immovable property "lmposto Predial"; and Taxes on passive income "lmposto sobre a Aplicagio de Capitais". (hereinafter referred to as "Angolan tax"J; 4. The Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date ofsignature ofthe Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notiff each other ofany significant changes that have been made in their respective taxation laws.

Ingingo ya 3: Igihe iri teka ritangirira gukurikizwa Article 3: Commencement Article 3 : Entrée en vigueur Official Gazette n° Special of 22/07/2022103 ITEKA RYA PEREZIDA Nº 040/01 RYO KU WA RYEMEZA 20/07/2022 BURUNDU AMASEZERANO HAGATI YA GUVERINOMA YA REPUBULIKA Y’U RWANDA NA GUVERINOMA YA REPUBULIKA YA ANGOLA YO GUCA BURUNDU GUSORESHA KABIRI KU KU BYEREKEYE MUSARURO RYO UMUSORO KUTISHYURA RY’UMUSORO, N’INYEREZWA I YASHYIRIWEHO KIGALI, MU RWANDA, KU WA 15 MATA 2022 IMISORO N’IKUMIRA UMUKONO BETWEEN RATIFYING PRESIDENTIAL ORDER Nº 040/01 Of THE 20/07/2022 AGREEMENT THE GOVERNMENT OF THE REPUBLIC OF RWANDA AND THE GOVERNMENT OF THE REPUBLIC OF ANGOLA FOR THE ELIMINATION DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX AVOIDANCE AND EVASION, SIGNED IN KIGALI, RWANDA, ON 15 APRIL 2022 OF ARRÊTÉ PRÉSIDENTIEL Nº 040/01 DU 20/07/2022 RATIFIANT L’ACCORD ENTRE LE GOUVERNEMENT DE LA RÉPUBLIQUE DU RWANDA ET LE LA GOUVERNEMENT RÉPUBLIQUE POUR L’ÉLIMINATION DE LA DOUBLE IMPOSITION EN MATIÈRE D’IMPÔTS SUR LE REVENU ET LA PRÉVENTION DE LA FRAUDE ET L’ÉVASION FISCALE, SIGNÉ À KIGALI, AU RWANDA, LE 15 AVRIL 2022 DE D’ANGOLA Twebwe, KAGAME Paul, Perezida wa Repubulika; We, KAGAME Paul, President of the Republic; Nous, KAGAME Paul, Président de la République ; Itegeko Nshinga Dushingiye ku rya Repubulika y’u Rwanda ryo mu 2003 ryavuguruwe mu 2015, cyane cyane mu ngingo zaryo, iya 112, iya 120, iya 122, iya 167, iya 168, n’iya 176; Dushingiye ku Itegeko nº 016/2022 ryo ku wa ryemera kwemeza burundu 29/06/2022 Amasezerano hagati ya Guverinoma ya Repubulika y’u Rwanda na Guverinoma ya Repubulika ya Angola yo guca burundu gusoresha kabiri ku byerekeye imisoro ku musaruro n’ikumira ryo kutishyura umusoro Pursuant to the Constitution of the Republic of Rwanda of 2003 revised in 2015, especially in Articles 112, 120, 122, 167, 168, and 176; Vu la Constitution de la République du Rwanda de 2003 en 2015, spécialement en ses articles 112, 120, 122, 167, 168, et 176 ; révisée Pursuant to Law nº 016/2022 of 29/06/2022 approving the ratification of the Agreement between the Government of the Republic of Rwanda and the Government of the Republic of Angola for the elimination of double taxation with respect to taxes on income and Vu la Loi nº 016/2022 du 29/06/2022 approuvant la ratification de l’Accord entre le Gouvernement de la République du Rwanda et la République d’Angola pour l’élimination de la double imposition en matière d’impôts sur le revenu et la prévention de la fraude et l’évasion le Gouvernement de Official Gazette n° Special of 22/07/2022104 yashyiriweho ry’umusoro, n’inyerezwa umukono i Kigali mu Rwanda, ku wa 15 Mata 2022; Tumaze kubona Amasezerano hagati ya Guverinoma ya Repubulika y’u Rwanda na Guverinoma ya Repubulika ya Angola yo guca burundu gusoresha kabiri ku byerekeye imisoro ryo kutishyura umusoro n’inyerezwa ry’umusoro, yashyiriweho umukono i Kigali mu Rwanda, ku wa 15 Mata 2022 ; ku musaruro n’ikumira the prevention of tax avoidance and evasion, signed in Kigali, Rwanda, on 15 April 2022; fiscale, signé à Kigali, au Rwanda, le 15 avril 2022 ; the Agreement between the Considering Government of the Republic of Rwanda and the Government of the Republic of Angola for the elimination of double taxation with respect to taxes on income and the prevention of tax avoidance and evasion, signed in Kigali, Rwanda, on 15 April 2022; Considérant l’Accord entre le Gouvernement de le la République du Rwanda et Gouvernement de la République d’Angola pour l’élimination de la double imposition en matière d’impôts sur le revenu et la prévention de la fraude et l’évasion fiscale, signé à Kigali, au Rwanda, le 15 avril 2022 ; Bisabwe na n’Igenamigambi; 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 meeting; Après examen et adoption par le Conseil des Ministres ; TWATEGETSE KANDI DUTEGETSE: HAVE ORDERED AND ORDER: AVONS ARRÊTE ET ARRÊTONS : Ingingo ya 3: Igihe iri teka ritangirira gukurikizwa Article 3: Commencement Article 3 : 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 la République du Rwanda. Journal Officiel de Official Gazette n° Special of 22/07/2022106 Kigali, 20/07/2022 (sé) KAGAME Paul Perezida wa Repubulika President of the Republic Président de la République (sé) Dr NGIRENTE Edouard 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 22/07/2022107 HAGATI W’ITEKA RYA UMUGEREKA PEREZIDA Nº 040/01 RYO KU WA BURUNDU 20/07/2022 RYEMEZA AMASEZERANO YA GUVERINOMA YA REPUBULIKA Y’U RWANDA NA GUVERINOMA YA REPUBULIKA YA ANGOLA YO GUCA BURUNDU GUSORESHA KABIRI KU KU BYEREKEYE MUSARURO RYO UMUSORO KUTISHYURA RY’UMUSORO, N’INYEREZWA YASHYIRIWEHO I KIGALI, MU RWANDA, KU WA 15 MATA 2022 IMISORO N’IKUMIRA UMUKONO BETWEEN ANNEX TO PRESIDENTIAL ORDER Nº 040/01 OF 20/07/2022 RATIFYING THE AGREEMENT THE GOVERNMENT OF THE REPUBLIC OF RWANDA AND THE GOVERNMENT OF THE REPUBLIC OF ANGOLA FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX AVOIDANCE AND EVASION, SIGNED IN KIGALI, RWANDA, ON 15 APRIL 2022 DE ENTRE ANNEXE À L’ARRÊTÉ PRÉSIDENTIEL Nº 040/01 DU 20/07/2022 RATIFIANT LE L’ACCORD GOUVERNEMENT LA RÉPUBLIQUE DU RWANDA ET LE LA GOUVERNEMENT RÉPUBLIQUE POUR L’ÉLIMINATION DE LA DOUBLE IMPOSITION EN MATIÈRE D’IMPÔTS SUR LE REVENU ET LA PRÉVENTION DE LA FRAUDE ET L’ÉVASION FISCALE, SIGNÉ À KIGALI, AU RWANDA, LE 15 AVRIL 2022 DE D’ANGOLA Official Gazette n° Special of 22/07/2022108 AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF RWANDA AND THE GOVERNMENT OF THE REPUBLIC OFANGOLA FOR THE ELIMANATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON AND THE PREVENTION OF TAX AVOIDANCE AND EVASION INCOME I Official Gazette n° Special of 22/07/2022109 PREAMBLE OF THE AGREEMENT The Government ofthe Republic of Rwanda and the Government ofthe Republic ofAngola, Desiring to further develop their economic relationship and to enhance their cooperation 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 ofresidents ofthird statesl, HAVE AGREED AS FOLLOWS: Chapter I SCOPE OF THE AGREEMENT Article 3 Income from Hydrocarbon Notwithstanding any other provision of this Agreement, nothing shall affect the right of either one ofthe Contracting States, or ofany oftheir local Governments or local authorities thereof to apply their domestic laws and regulations related to the taxation on income and profits derived from hydrocarbons and its associated activities situated in the territory of their respective Contracting State, as the case may be. Chapter II DEFINITIONS

Article 4 General Definitions 1. For the purposes of this Agreement, unless the context otherwise requires: J { Official Gazette n° Special of 22/07/2022111 (a) (bl (c) td) 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 "Angola" means the Republic of Angola and, when used in a geographical sense, includes the territorial sea thereof as well as any area outside the territorial sea, including the continental shelf, which has been or may hereafter be designated, under the laws ofAngola and in accordance with international law, as an area within which Angola may exercise sovereign rights or jurisdiction; the terms "a Contracting State" and "the other Contracting State" mean Rwanda or Angola as the context requires; the term "person" includes an individual, a company and any other body of persons that is treated as an entity for tax purposes; (e) the term "company" means anybody corporate or any entity which is treated as a body corporate for the tax purposes; t0 (gl (h) the term "enterprise" applies to the carrying on ofany business; the terms "eirterprise of a Contracting State,, and .,enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; the term "international traffic" means any transport by a ship, aircraft, rail or road transport vehicle operated by an enterprise ofa Contracting State, except when the ship, aircraft, rail or road transport vehicle is operated solely between places in the other Contracting State; (D the term "competent authority'', means: (il (iiJ in Rwanda, the Minister in Charge of Finance or his authorised representative, and in In Angola, the Minister of Finance, by delegation of powers of the President ofthe Republic ofAngola or his authorised representative; 0l the term "national" means: (il any individual possessing the nationality ofa Contracting State; fi 4 Official Gazette n° Special of 22/07/2022112 (iD any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State. (k) the term "business" includes the performance ofprofessional services and of other activities of an independent character; 2, As regards the application of the provisions of the Agreement at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law ofthat State for the purposes of the taxes to which the Agreement applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to t}re term under other laws of that State.

Article 5 Resident 1, For the purposes of this Agreement, the term "resident of a Conffacting State" means any person who, under the laws ofthat State, is liable to tax therein by reason ofthat person's domicile, residence, place of incorporation, place of management or any other criterion of a. similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then that individual's status shall be determined as follows: (a) the individual shall be deemed to be a resident only of the State in which a permanent home is available to the individual; if a permanent home is available to the individual in both states, the individual shall be deemed to be a resident only of the State with which the individual's personal and economic relations are closer (centre of vital interests); [b] ifthe State in which the centre ofvital interests is situated cannot be determined, or if the individual has not a permanent home available in either State, the individual shall be deemed to be a resident only of the State in which the individual has an habitual abode; (c) if the individual has an habitual abode in both States or in neither of them, the individual shall be deemed to be a resident only of the State of which the individual is a national; 'd 5 Official Gazette n° Special of 22/07/2022113 (d) if the individual is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3. Where by reason ofthe provisions of paragraph 1 a person other than an individual is a resident ofboth Contracting States, the competent authorities ofthe Contracting States shall endeavour to determine by mutual agreement the Contracting State 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 ofsuch agreement, such person shall not be entitled to any reliefor exemption from tax provided by this Agreement except to the extent and in such manner as may be agreed upon by the competent authorities ofthe Contracting States.

Article 6 Permanent Establishment l-. For the purposes of this Agreement, the term 'permanent establishment' means a fixed place ofbusiness through which the business ofan enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; t0 activities are carried on; a sales outlet 0) a mine, an oil or gas well, a quarry or any other place of extraction or exploitation of natural resources; tg) a warehouse in relation to a person providing storage facilities for others; O) a farm, plantation or other place where agricultural, forestry or related 3. The term "permanent establishment" shall be deemed to include: a building site, a construction, assembly or installation project or any supervisory activity in connection with such site or project, but only where such site, proiect or activity continues for a period of more 183 days in any twelve-month period commencing or ending in the fiscal year concerned; the furnishing of services, including consultanry services, by an enterprise through employees or other personnel engaged by an enterprise for such 6 (al (bl ( Official Gazette n° Special of 22/07/2022114 purpose, but only where activities of that nature continue (for the same or a connected project) within the Contracting State for a period or periods exceeding in the aggregate than ninety (90) days in any twelve-month period commencing or ending in the fiscal year concerned; (cJ for an individual, the performing of services in a Contracting State by that individual, but only if the individual's stay in that State, for the purpose of performing those services, is for a period or periods aggregating more than ninety (90) days in any twelve-month period commencing or ending in the fiscal year concerned. (d) an installation or structure used in the exploration for natural resources provided that the installation or structure continues for a period of not less than than ninety (90) days in any twelve-month period commencing or ending in the fiscal year concerned; eJ Substantial equipment or machinery that is operated, or is available for operation, in a Contracting State for a period or periods aggregating more than 90 days in any 12-month period commencing or ending in the fiscal year concerned. The duration of activities under subparagraphs (aJ, (b1, (c), (d) and (e) shall be determined by aggregating the periods during which activities are carried on in a Contracting State by closely related enterprises, provided that the activities of such closely related enterprise in that Contracting State are connected with the activities carried on in that Contracting State by its closely related enterprise. The period during which two or more closely related enterprise are carrying on concurrent activities shall be counted only for the purpose of determining the duration of activities. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment'' shall be deemed not to include: [a) the use of facilities solely for the purpose of storage, display of goods or merchandise belonging to the enterprise; tb) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display; (cl the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; 7 Official Gazette n° Special of 22/07/2022115 (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise, or of collecting information, for the enterprise; and (e) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs [a) to [d). provided that such activity or, in the case of subparagraph (e), the overall activity of the fixed place of business, is of a preparatory or auxiliary character. 5. Paragraph 4 shall not apply to a fixed place of business that is used or maintained by an enterprise ifthe same enterprise or a closely related enterprise carries on business activities at the same place or at another place in the same Contracting State and (a) that place or other place constitutes a permanent establishment for the enterprise or the closely related enterprise under the provisions ofthis Article, or (bl the overall activity resulting from the combination ofthe 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, 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. 6. Notwithstanding the provisions of paragraphs 1 and 2 but subject to the provisions of paragraph 7 where a person is acting in a Contracting State on behalf of an enterprise, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State in respect of any activities which the person undertakes for the enterprise, if such person: 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: in the name ofthe enterprise, or (D (iD 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 (iii) for the provision ofservices by that enterprise, 8 (a) \ Official Gazette n° Special of 22/07/2022116 unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph; or (b) the person does not conclude contracts not plays the principal role leading to the conclusion of such contracts, but habitually maintains in the first- mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise. 7. (a) Paragraph 6 shall not apply where the person acting in a Contracting State on behalfofan enterprise ofthe other Contracting State carries on business in the first-mentioned State as an independent agent and acts for the enterprise in the ordinary course of that business. Where, however, a person acts exclusively or almost exclusively on behalfofone 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. (bl For the purposes ofthis Article, a person is closely related to an enterprise if, based on all the relevant facts and circumstances, one has control ofthe other or both are under the control ofthe same persons or enterprises. In any case, a person shall be considered to be closely related to an enterprise if one possesses directly or indirectly more than 50 per cent ofthe 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 ifanother person possesses directly or indirectly more than 50 per cent ofthe beneficial interest ( or, in the case of a company, more than 50 per cent ofthe aggregate vote and value ofthe company's shares or of the beneficial equity interest in the company) in the person and the enterprise. 8. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in regard to re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent ofan independent status to whom paragraphs 7 and 9 applies. 9. An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting State merely because it carries on business in that other State through a broker, general commission agent or any other agent ofan independent status, provided that such persons are acting in the ordinary course of their business. ( 9 w Official Gazette n° Special of 22/07/2022117 10. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. Chapter lI TAXATION OF INCOME

ARTICLE 7 INCOME FROM IMMOVABLE PROPERTY 1. Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State. 2, The term "immovable property" shall have the meaning which it has under the law of the Contracting State 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 ol or the right to work, mineral deposits, sources and other natural resources. Ships, aircraft, rail or road transport vehicles 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. 4. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an enterprise.

ARTICLE 8 BUSINESS PROFITS 1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State 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 State but only so much ofthem as is attributable to: that permanent establishment; sales in that other State of goods or merchandise of the same or similar kind as those sold through that permanent establishment; l0 a) bl I Official Gazette n° Special of 22/07/2022118 ) 3 4 c) other business activities carried on in that other State of the same or similar kind as those effected through that permanent establishmenL Subiect to the provisions of paragraph 3, where an enterprise of a Contracting State .r#i", on business in the other CJntiacting State through a permanent establishment ,ituat"d tf,"."in, there shall in each Contracting State be atfiibuted to that permanent u,t"rri,n."nttheprofitswhichitmightbeexpectedtomakeifitwereadistinctand separate enterprise engaged in the same or similar activities under the same or .i,iii". .onaitions and deiling *holly independently with the enterprise of which it is a permanent establishmenL "*p"n.", "rLblirh*"nt, In determining the profits of a permanent establishment' there shall be allowed as which are incurred for the purposes of the business of the ;;J;;ir"t including executive and general administrative expenses ;;;;;;;, Ioln.r*"a, whether in the Contraciing State in which the permanent establishment is situated or elsewhere. However, nJsuch deduction shall be allowed in respect of amounts, ifany, paid [otherwise than towards reimbursement ofactual expenses) by ;h; ;;;r""ri'"rtruirn-"nt 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 ;;Ii-ts;; oth"r rigl,is, or by *ay 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 p".rn"n"n, establishment' Likewise' no account shall be taken' in the determination of the ptonlt of ' permanent establishment' for amounts charged i"ir,".*ir. ,r,"n towardi reimbursement of actual expenses), by the permanent establishment to the head office of the enterprise or any of its other offices, by way of ;;il;i;r; fees or other simi-la. prymerrts-in rerurn for the use of patents or other ;il;;;; by way of commissionfor specific services performed or for management' by way of interest on moneys lent to the or, except in the case of a Urnf.ing head office of the enterprise or any of its other offices' In so far as it has been customary in a contracting state-to determine the profits to be on the b-asis of an apportionment.of the total attributed to a p..rn"n"n, profits of the enterprise ,o-i,t t"iout parts' nothing in paragraph 2 sh.all preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be .,tt"Inary' the"method of apportionment adopted shall' however, be such that the t*'ii tn'ff be in accordance with the principles contained in this Article. "ri"utishment "nt"tprise 5, For the purposes of the preceding paragraphs'.the profits to be-attributed to the Dermanent estabtishmeni shall be" aeteiminea by the same method year by year unless there is good and sufficient reason to the contrary' 6.Whereprofitsincludeitemsofincomewhicharedealtwithseparatelyinother Articles of this Agreemer,, ii", ,r," p."visions of those Articles shall not be affected by the provisions of this Article' ll 4 Official Gazette n° Special of 22/07/2022119

ARTICLE 9 INTERNATIONAL TRANSPORT 1. profits of an enterprise of a contracting state from the operation of ships, aircraft, rail or road transport vehicles in international traffic shall be taxable only in that state' 2'ForthepurposesofthisArticle,profitsfromtheoperationofships,aircraftorrailor road transport vehicles in international traffic shall include: (a)profitsderivedfromtherentalonabareboatbasisofshipsoraircraftusedin international traffic, (b)profitsderivedfromtherentalofrailorroadtransportvehiclesusedin international traffic, (c) profits derived from the use or rental ofcontainers' ifsuch profits are incidental to the profits to which the provisions ofparagraph l apply' 3. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a ioint business or an international operating agency'

Article 10 Associated EnterPrises 1. Where (a)anenterpriseofaContractingStateparticipatesdirectlyorindirectlyinthe management,controlorcapitalofanenterpriseoftheotherContractingState' or (b)thesamepersonsparticipatedirectlyorindirectlyinthemanagement,control or capital ofan enterprisl of a Contracting State and an enterprise ofth6 other Contracting State, 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 ofthe enterprises, but, by reason ofthose conditions, not io accrued, may be included in the profits of that enterprise and taxed t "u" accordingly. t2 Official Gazette n° Special of 22/07/2022120 2. Where a Contracting State includes in the profits of an enterprise of that State - and taxes accordingly - profits on which an enterprise ofthe other Contracting State has been charged to tax in that other State and the profits so included are profits which would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then that other State shall make an appropriate adjustment to the amount ofthe tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provisions ofthis Agreement and the competent authorities of the Contracting States shall, if necessary, consult each other. 3. The provisions of paragraph 2 shall not apply where judicial, administrative or other legal proceedings have resulted in a final ruling that by actions giving rise to an adjustment ofprofits under paragraph 1, one of the enterprises concerned is liable to penalty with respect to fraud, gross negligence or wilful default.

ARTICLE 11 DIVIDENDS 1. Dividends paid by a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. 2. However, dividends paid by a company which is a resident of a Contracting State may also be taxed in that State according to the laws of that State, but if the beneficial owner ofthe dividends is a resident ofthe other Contracting State, the tax so charged shall not exceed 10%o ofthe gross amount ofsuch dividends. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. The term "dividends" as used in this Article means income from shares, "louissance" shares or "jouissance" rights, mining shares, founders' 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 State of which the company making the distribution is a resident. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner ofthe dividends, being a resident of a Contracting State, carries on business in the other Contracting State 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 B shall apply. 4o l3 ?a Official Gazette n° Special of 22/07/2022121 5. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company, except in so far as such dividends are paid to a resident ofthat other State or in so far as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment situated in that other State, nor subject the company's undistributed profits to a tax on undistributed profits, even if the dividends paid or the undistributed profits consistwholly or partly of profits or income arising in such other State.

ARTICLE 12 INTEREST 1. lnterest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such interest may also be taxed in the Contracting State in which it arises, and according to the laws ofthat State, but if the beneficial owner ofthe interest is a resident ofthe other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the interest. 3. Notwithstanding the provisions ofparagraph 2, interest arising in a Contracting State shall be exempt from tax in that State if it is derived by the Government of the other Contracting State or a political subdivision or a local authority thereof, the Central Bank of the other Contracting State or any institution wholly owned by the Government of the other Contracting State or a political subdivision or a local authority thereof. 4. 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 purposes ofthis Article. 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State 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 8 shall apply. 6, Interest shall be deemed to arise in a Contracting State when the payer is a resident ofthat State. Where, however, the person paying the interest, whether that person is l4 Official Gazette n° Special of 22/07/2022122 a resident cf a f,or-.racting State or nci-, has in a Contracting State a permanent establishment in corrnection luith w-hich the indebtedness on which the interest is paid was incurred, and such interest shall be deemed to arise in the State in which the permanent establishment is situated. Where, by reason of a special relationship between the payer and the beneficial owner or between both ofthem and some other person, the amount ofthe interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence ofsuch relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part ofthe payments shall remain taxable according to the laws ofeach Contracting State, due regard being had to the other provisions of this Agreement.

ARTICLE 13 ROYALTIES 1. Royalties arising in a Contracting State and paid to a resident ofthe other Contracting State may be taxed in that other State. 2. However, royalties arising in a Contracting State may also be taxed in that State according to the laws of that State, but if the beneficial owner of the royalties is a resident ofthe other Contracting State, the tax so charged shall not exceed 10 per cent ofthe gross amount ofthe royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for aJ b) c) d) the use of, or the right to use, any copyright of literary, artistic, scientific work including cinematograph films, or films, or tapes used for radio or television broadcasting, any patent, trac:mark, design or model, plan, secret formula or process, or other kind like prc-terty or right, the use of right to use, the receipt or the right to receive, visual image or sound, or both, that are transmitted to the public by satellite, or cable, optic fibre or similar technologz, the use or the right to use, in connection with television, radio, or internet broadcasting visual images or sound, or both, that are transmitted by satellite or by cable, optic fibre or similar technology, the use of, or the right to use, industrial, technical, commercial or scientific equipment, or, 15 Official Gazette n° Special of 22/07/2022123 e) 0 information concerning indusffial, technical, commercial or scientific experience, sale, transfer or exchange of property or right of a similar nature to those referred to in sub-paragraph (a) - (eJl 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State 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 (a) such permanent establishment or with (b) business activities referred to in (cJ of paragraph 1 ofArticle 8. In such case, the provisions of Article B shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person palng the royalties, whether that person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State 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 ofthem and some other person, the amount ofthe 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 appty only to the last-mentioned amount. In such case, the excess part ofthe payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Article 14 Fees for Technical Service 1, Fees for Technical Service arising in a Contracting State and paid to a resident ofthe other Contracting State may be taxed in that other State. 2. However, fees for technical services arising in a Contracting State may also be taxed in that State according to the laws of that State, but if the beneficial owner of the technical fees is a resident ofthe other Contracting State, the tax so charged shall not exceed 10 per cent ofthe gross amount ofthe technical fees. h l6 Official Gazette n° Special of 22/07/2022124 3. The term "fees for technical services" as used in this Article means any payment in consideration for any service ofa managerial, technical or consultancy nature, unless the payment is made: a to an employee of the person making the paymenq b. for teaching in an educational institution or for teaching by an educational institutioU or c. by an individual for services for the personal use of an individual. 4, The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise through a permanent establishment situated in that other State, and the fees for technical services are effectively connected with a. such permanent establishment, or b. business activities referred to in [cl of paragraph 1 of Article 8 In such cases the provisions of Article 8 as the case may be, shall apply. 5. For the purposes of this Article, subject to paragraph 6, fees for technical services shall be deemed to arise in a Contracting State if the payer is a resident ofthat State or if the person paying the fees, whether that person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligations to pay the fees was incurred, and such fees are borne by the permanent establishment. 6, For the purposes ofthis Article, fees for technical services shall be deemed not to arise in a Contracting Srate ifthe payer is a resident ofthat State and carries on business in the other Contracting State through a permanent establishment situated in that other State 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 ofthe fees, 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 ofthe fees shall remain taxable accordingto the laws ofeach Contracting State, due regard being had to the other provisions ofthis Agreement t7 * Official Gazette n° Special of 22/07/2022125

Article 15 Capital Gains 1. Gains derived by a resident ofa Contracting State from the alienation of immovable property referred to in Article 7 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part ofthe business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State, including such gains from the alienation ofsuch a permanent establishment [alone or with the whole enterprise), may be taxed in that other State. 3. Gains that an enterprise of a Contracting State that operates ships, aircraft, rail or road transport vehicles in international traffic derives from the alienation of such ships, aircraft, rail or road transport vehicles or of movable property pertaining to the operation of such ships, aircraft, rail or road transport vehicles, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests, such as interests in a partnership or trust, may be taxed in the other Contracting State 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 7, situated in that other State. 5. Gains other than to which paragraph 4 applies, derived by a resident of a Contracting State from the alienation of shares of a company which is a resident of the other Contracting State, may be taxed in that other Contracting State. 6. Gains from the alienation of any property other than that referred to in the preceding paragraphs of this Article, shall be ta'able only in the Contracting State of which the alienator is a resident.

Article 16 Dependent Personal Services 1. Subject to the provisions ofArticles 17,19,20,21 and 22, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. Ifthe employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. Official Gazette n° Special of 22/07/2022126 ,s 2. Notwithstanding the provisions of paragraph 1., remuneration derived by a resident ofa Contracting State in respect ofan employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal year concerned, an, -. tbl the remuneration is paid by, or on behalf of, an employer who is'not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment which the employer has in the other State. 3. Nonvithstanding the preceding provisions of this Article, remuneration derived by a resident of a Contracting State in respect of an employment, as a member of the regular complement of a ship or aircraft, that is exercised aboard a ship or aircraft operated in international traffic, other than aboard a ship or aircraft operated solely within the other Contracting State, shall be taxable only in the first-mentioned State.

Article 17 Directors' Fees and Remuneration ofTop-Level Managerial Officials 1. Directors' fees and similar payments derived by a resident ofa Contracting State in that person's capacity as a member of the board of directors, or similar body of a company which is a resident of the other Contracting State may be taxed in that other State. 2. Salaries, wages and other similar remuneration derived by a resident ofa Contracting State in the individual's capacity as an official in a top-level managerial position ofa company which is a resident of the other Contracting State may be taxed in that other State.

Article 18 Entertainers and Sportspersons 1. Notwithstanding the provisions of Articles 8 and 16, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson, from that person's personal activities as such exercised in the other Contracting State, may be taxed in that other State. \ l9 Official Gazette n° Special of 22/07/2022127 2. Where income in respect of personal activities exercised by an entertainer or a sportsperson in that person's capacity as such accrues not to the entertainer or sportsperson but to another person, that income may, noBvithstanding the provisions ofArticles 8 and 16 be taxed in the Contracting State in which the activities ofthe entertainer or sportsperson are exercised. 3. Income derived by a resident of a Contracting State from activities exercised in the other Contracting State as envisaged in paragraphs 1and2, shall be exempt from tax in that other State if the visit to that other State is supported wholly or mainly by public funds ofthe first-mentioned Contracting State, a political subdivision or a local authority thereol or takes place under a cultural agreement or arrangement between the Governments ofthe Contracting States. ln such a case, the income shall be taxable only in the Contracting State of which the artiste or sportsperson is a resident Arricle 19 Pensions and other similar remuneration 1, Subject to the provisions of paragraph 2 of Article 20, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State. 2. Notwithstanding the provision of paragraph 1, pensions paid and other payments made under public scheme, which is part ofthe social security system ofa Contracting State or a local authority thereof, shall be taxable only in that State. 3. NoBvithstanding any provision of this Agreement, pension and other similar remuneration paid to a resident of a Contracting State in consideration of past employme."t exercised in the other Contracting State shall be exempt from tax in the first-mentiuned State if that pension or other similar remuneration would be exempt from tax in the other State if the recipient were a resident ofthat other State.

Article 20 Government Service 1. (a) Salaries, wages and other similar remuneration, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. q 20 Official Gazette n° Special of 22/07/2022128 1.,' b) iic.rv: 'e;, :'-rcl-i saiaries, .ragcs ald ather similar remuneration shall be taxable only inr.he ottrer Contracting State if the services are rendered in that other State and the rnCirriCual is a resident ofthat State who: (i) is a national ofthat State; or (ii) did not become a resident ofthat State solely for the purpose ofrendering the services. 2. (a) Any pension paid by, or out of funds created by, a Contracting State or a political subdivision or a local authority thereofto an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. (b) However, such pension shall be taxable only in the other Contracting State if the individual is a resident ol and a national ol that State. 3. The provisions ofArticles 16,17,lB and 19shall applyto salaries, wages, pensions, and other similar remuneration in respect ofservices rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authorify thereof.

Article 21 PROFESSORS AND RESEARCHERS 1. An individual who visits a Contracting State for a period not exceeding tlvo years for the sole purpose ofteaching or carrying out research at a university, college school or other recognized educational institution in that State and who is or was immediately before that visit a resident ofthe other Contracting State, shall be exempt from tax in the first-mentioned State on any remuneration for such teaching or research, provided that such remuneration is derived by the individual from research if such activities are undertaken by ihe individual from outside that State and is subject to tax thereon in the State of res,dence of the individual. 2. The provisions of paragraph 1 of this article shall not apply to income from research ifsuch research is undertaken not in the public interest but primarily for the private benefit of a specific person or persons.

Article 22 Students and Business Apprentices 1. A student or business apprentice who is present in a Contracting State solely for the purpose ofthe student's or business apprentice's education or training and who is, or immediately before being so present was, a resident of the other Contracting State, ?.\ ) Official Gazette n° Special of 22/07/2022129 shall be exempt from tax in the first-mentioned State on payments received from outside that first-mentioned State fcr ths'- pmposes .of the student or business apprentice's maintenance, education or training. . . '. 2. In respect of grants, scholarships and remuneration from employment not covered by paragraph 1, a student or business trainee or apprentice described in paragraph 1 shall, in addition, be entitled during such education or training to the same exemptions, reliefs or reductions in respect oftaxes available to residents ofthe State he is visiting.

Article 23 Other Income 1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that State. 2. The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 7, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein and the right or property in respect of which the income is paid is effectively connected with such permanent establishment. In such case the provisions of Article 8 shall apply. 3. Notwithstanding the provisions of paragraphs L and 2, items of income of a resident of a Contracting State not dealt with in the foregoing Articles of the Agreement and arising in the other Contracting State may also be taxed in that other State. Chapter IV METHODS FORTHE ELIMINATION OF DOUBLE TAXTTION

ARTICLE 24 ELIMINATION OF DOUBLE TAXIITION 1. Double taxation shall be eliminated as follows: (al in Rwanda: Tax paid by a resident of Rwanda in respect of income taxable in Angola, in accordance with the provisions of this Agreement, shall be deducted from taxes due in accordance with Rwandan Tax Law (which shall not affect the general principle hereof). Such deduction shall not, however, exceed the tax payable in Rwanda that would otherwisb lie payable on the income taxable in Angola. q 22 Official Gazette n° Special of 22/07/2022130 [b] ln Angola: !'ly'here a resident of Angola derives income which, in accordance with the provisions ofthis Agreement, may be taxed in the other Contracting State, Angola Shall allow as a deduction from the tax on the income ofthat resident an amount equal to the income tax paid in that other State. Such deduction shall not, however, exceed that part ofthe income tax, as computed before the deduction is given, which is attributable to the income which may be taxed in that other State; 2. Where in accordance with any provisions of the Agreement income derived or capital owned by a resident ofa Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. 3. For the purposes of paragraph L, the terms "Rwanda tax paid" and "Angola" shall be deemed to include the amount of tax which would have been paid in Rwanda or in Angola, as the case may be, but for an exemption or reduction granted in accordance with laws which establish schemes for the promotion of economic development in Rwanda or in Angola, as the case may be, such schemes having been mutually agreed by the competent authorities ofthe Contracting States as quali$ring for the purposes of this paragraph. Chapter V SPECIAL PROVISIONS

Article 25 NON.DISCRIMINATION 1. Nationals ofa Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which nationals ofthat other State 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 ofone or both ofthe Contracting States. 2. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises ofthat other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents ofthe other Contracting State any personal allowances, reliefs and . reductions for taxation purposes on account of civil status or family responsibilities . , . which it grants to its own residents. ( Z) Official Gazette n° Special of 22/07/2022131 3. Except where the provisions of paragraph 1 of Article 10, paragraph 6 of Article 12, paragraph 6 of Article 13 or paragraph 7 of Article 14 apply, interest, royalties, technical fees and other disbursements paid by an enterprise of a Contracting State to a resident ofthe other Contracting State shall, for the purpose of determining the taxable profits ofsuch enterprise, be deductible under the same conditions as ifthey had been paid to a resident ofthe first-mentioned State. 4, Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents ofthe other Contracting State, shall not be subjected in the first-mentioned State 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 ofthe first- mentioned State are or may be subjected. 5. The provisions ofthis Article shall, notwithstanding the provisions ofArticle 2, apply to taxes ofevery kind and description.

Article 26 Mutual Agreement Procedure 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this Agreement, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 25, to that of the Contracting State of which the person is a national. 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 atrthority shall endeavour, ifthe 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 State, 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 domestic law ofthe Contracting States. 3. The competent authorities of the contracting states shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreemenl 4. The competent authorities of the contracting states may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding 21 Official Gazette n° Special of 22/07/2022132 paragraphs. The competent authorities may develop appropriate bilateral procedures, conditions, methods and techniques for implementation of mutual agreement procedure provided for in this Article.

Article 27 Exchange of Information 1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions ofthis Agreement or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, or of their political subdivisions in so far as the taxation thereunder is not contrary to the Agreement The exchange of information is not restricted by Articles L and 2. 2, Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State 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 ofappeals in relation to the taxes referred to in paragraph 1, or the oversight ofthe 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 State may be used for other purposes, when such information may be used for such other purposes under the laws of both States and the competent authority of the supplying Contracting State authorises such use. 3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation: (a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; (b) 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 State; (cl to supply information which would disclose any trade, business, indusffial, commercial or professional secret or trade process, or information the disclosure of which would be contrary to public policy fordre public). 4. If information is requested by a Conracting State in accordance with this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State 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 25 4 Official Gazette n° Special of 22/07/2022133 construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information. 5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting State 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 28 Assistance in the Collection of Taxes 1. The Contracting States shall lend assistance to each other in the collection of revenue claims. This assistance is not restricted by Articles I and 2. The competent authorities of the Contracting States may by mutual agreement settle the mode of application of this Article. 2. The term "revenue claim" as used in this Article means an amount owed in respect of taxes ofevery kind and description imposed on behalfofthe Contracting States, or of their political subdivisions or Iocal authorities, in so fur as the taxation thereunder is not contrary to this Agreement or any other instrument to which the Contracting States are parties, as well as interest, administrative penalties and costs of collection or conseryancy related to such amount. 3. When a revenue claim of a Contracting State is enforceable under the laws of that State and is owed by a person who, at that time, cannot, under the laws of that State, prevent its collection, that revenue claim shall, at the request of the competent authority of that State, be accepted for purposes of collection by the competent authority of the other Contracting State. That revenue claim shall be collected by that other State in accordance with the provisions of its laws applicable to the enforcement and collection of its own taxes as if the revenue claim were a revenue claim of that other State. 4. When a revenue claim ofa Contracting State is a claim in respect of which that State may, under its law, take measures of conservancy with a view to ensure its collection, that revenue claim shall, at the request of the competent authority of that State, be accepted for purposes of taking measures ofconservancy by the competent authority ofthe other Contracting State. That other State shall take measures of conservancy in respect ofthat revenue claim in accordance with the provisions of its laws as ifthe revenue claim were a revenue claim ofthat other State even if, at the time when such measures are applied, the revenue claim is not enforceable in the first-mentioned State or is owed by a person who has a right to prevent its collection. 5. Notwithstanding the provisions of paragraphs 3 and 4, a revenue claim accepted by a Contracting State for purposes of paragraph 3 or 4 shall not, in that State, be subject 26 Official Gazette n° Special of 22/07/2022134 to the time limits or accorded any priority applicable to a revenue claim under the laws ofthat State by reason of its nature as such. In additioru a revenue claim accepted by a Contracting State for the purposes of paragraph 3 or 4 shall not, in that State, have any priority applicable to that revenue claim under the laws of the other Contracting State. 6. Proceedings with respect to the existence, validity or the amount of a revenue claim of a Contracting State shall not be brought before the courts or administrative bodies of the other Contracting State. 7, Where, at any time after a request has been made by a Contracting State under paragraph 3 or 4 and before the other Contracting State has collected and remitted the relevant revenue claim to the first-mentioned State, the relevant revenue claim ceases to be: (al in the case of a request under paragraph 3, a revenue claim of the first- mentioned State that is enforceable under the laws ofthat State and is owed by a person who, at that time, cannot, under the laws ofthat State, prevent its collection, or (b) in the case of a request under paragraph 4, a revenue claim of the first- mentioned State in respect of which that State may, under its laws, take measures of conservancy with a view to ensure its collection. the competent authority of the first-mentioned State shall promptly noti$z the competent authority ofthe other State ofthat fact and, atthe option ofthe other State, the first-mentioned State shall either suspend or withdraw its request.\ 8. In no case shall the provisions of this Article be construed so as to impose on a Contracring State the obligation: [a) to carry out administrative measures at variance with the laws and administrative practice ofthat or ofthe other Contracting State; (b) to carry out measures which would be contraryto public policy fordre publicJ; (c) to provide assistance if the other Contracting State has not pursued all reasonable measures of collection or conservancy, as the case may be, available under its laws or administrative practice; 27 3 Official Gazette n° Special of 22/07/2022135 (dl to provide assistance in those cases where the administrative burden for that State is clearly disproportionate to the benefit to be derived by the other Contracting State.

Article 29 Members of Diplomatic Missions and Consular Posts Nothing in this Agreement shall affectthe fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements. Chapter IV FINAL PROVISIONS

Article 30 ENTITLEMENT TO BENEFITS Notlvithstanding any provisions ofthis Agreement, a benefit under this Agreement shall not be granted in respect ofan 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 benefi! unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose ofthe relevant provisions ofthis Agreement.

Article 31 Entry into Force 1. Each of the Contracting States shall notiflz to the other, through the diplomatic channel, 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 receipt of the later of these notifications. 2. The provisions of the Agreement shall apply: (a) with regard to taxes withheld at source, in respect ofamounts paid or credited on or after the 1st day of January next following the date upon which the Agreement enters into force; and (bl with regard to other taxes, in respect of income in any taxable year beginning on or after the 1$ day of January next following the date upon which the Agreement enters into force. 28 k Official Gazette n° Special of 22/07/2022136

Article 32 'I'ermination l.ThisAgreementshallremaininforceindefinitely,buteitheroftheContractingStates may terminate the Agreement through the diplomatic channel' by giving to the other Contracting State written notice of termination not later than 30 fune of any calendar year startiig five years after the year in which the Agreement entered into force' 2. ln such event the Agreement shall cease to apply: (a) with regard to taxes withheld at source, in respect ofamounts paid.or. credited on, or after the 1.t day oflanuary next following the day upon which the notice is received; and (b) with regard to other taxes, in respect of income in any taxable year beginning th"e t" day of fanuary next following the day upon which the notice is i-ri, o. received. "n". INwlTNEsswHEREoFtheundersigned,beingdulyauthorizedthereto,havesigned Agreement. this DONE at Kigali in duplicate, this 15th day of Aprtl2022' FORTHE GOVERNMENT OT C OF RWANDA THE RE FORTHE GOVERNMENT THE UBLIC OF Dr. Vincent Biruta Minister of Foreign Affairs and International CooPeration T6te Ant6nio Minister of External Relations 29 Official Gazette n° Special of 22/07/2022137 Bibonywe kugira ngo bishyirwe ku mugereka w’Iteka rya Perezida nº 040/01 ryo ku wa 20/07/2022 ryemeza burundu Amasezerano hagati ya Guverinoma ya Repubulika y’u Rwanda na Guverinoma ya Repubulika ya Angola yo guca burundu gusoresha kabiri ku byerekeye imisoro ku kutishyura musaruro n’ikumira ry’umusoro, umusoro n’inyerezwa yashyiriweho umukono i Kigali mu Rwanda, ku wa 15 Mata 2022 ryo of ratifying 20/07/2022 Seen to be annexed to Presidential Order nº 040/01 the Agreement between the Government of the Republic of Rwanda and the Government the of elimination of double taxation with respect to taxes on income and the prevention of tax avoidance and evasion, signed in Kigali, Rwanda, on 15 April 2022 the Republic of Angola for le Gouvernement de Vu pour être annexé à l’Arrêté Présidentiel nº 040/01 du 20/07/2022 ratifiant l’Accord entre le Gouvernement de la République du Rwanda et la République d’Angola pour l’élimination de la double imposition en matière d’impôts sur le revenu et la prévention de la fraude et l’évasion fiscale, signé à Kigali, au Rwanda, le 15 avril 2022 Official Gazette n° Special of 22/07/2022138 Kigali, 20/07/2022 (sé) KAGAME Paul Perezida wa Repubulika President of the Republic Président de la République (sé) Dr NGIRENTE Edouard 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 22/07/2022139