Burundi Cross-Border Tax Guide 2026

Overview — Cross-Border Taxation in Burundi

Burundi's cross-border tax rules are governed by the Code Général des Impôts and administered by the Office Burundais des Recettes (OBR). Unlike territorial jurisdictions, Burundi taxes residents on worldwide income. Multinational enterprises operating in Burundi must comply with transfer pricing documentation requirements and withholding tax obligations. As a member of COMESA (Common Market for Eastern and Southern Africa) and the East African Community (EAC), Burundi applies regional trade agreements and investment protocols.

Transfer Pricing — Arm's Length Principle

Burundi's transfer pricing rules require that transactions between related parties be priced at arm's length. Related parties include companies under common control, parent-subsidiary relationships, and individuals with significant influence. Documentation requirements include contemporaneous documentation for transactions exceeding specified thresholds. Acceptable transfer pricing methods include the Comparable Uncontrolled Price (CUP) method, Cost Plus method, Resale Price method, and Transactional Net Margin Method (TNMM). Penalties for non-compliance can be significant. OBR has been building its transfer pricing audit capacity.

Withholding Taxes to Non-Residents

Payments to non-residents from Burundi-source income are subject to withholding tax at the following standard rates (treaty rates may apply):

• Dividends — 15%
• Interest — 15%
• Royalties — 15%
• Management fees — 15%
• Technical service fees — 15%
• Rent (commercial property) — 15%

The person making the payment must withhold the tax and remit it to OBR within 15 days. A withholding tax certificate must be issued to the non-resident.

COMESA & EAC Regional Framework

As a member of COMESA and the EAC, Burundi participates in regional economic integration including:

• Free trade area — preferential tariff treatment for goods originating from COMESA and EAC member states
• Investment facilitation — regional investment protocols providing protections for cross-border investors
• Tax cooperation — regional initiatives for tax information exchange and combating tax evasion
• Common external tariff — harmonised customs duties on imports from outside the regions

COMESA member states include Burundi, Comoros, DRC, Djibouti, Egypt, Eritrea, Ethiopia, Kenya, Libya, Madagascar, Malawi, Mauritius, Rwanda, Seychelles, Somalia, South Sudan, Sudan, Eswatini, Uganda, Zambia, and Zimbabwe. EAC partner states include Burundi, Kenya, Rwanda, South Sudan, Tanzania, Uganda, and the Democratic Republic of the Congo.

Double Tax Treaties

Burundi has a limited network of double tax treaties. As of 2026, Burundi has signed comprehensive DTTs including with Belgium and France. Burundi also has tax information exchange agreements (TIEAs) with several jurisdictions. To claim treaty benefits, a non-resident must obtain a Certificate of Tax Residency from their home country tax authority and submit a treaty relief application to OBR.

FAQs

Do I need to register for tax in Burundi as a non-resident investor?

Non-residents earning Burundi-source income subject to final withholding tax generally do not need to register. However, a non-resident with a permanent establishment in Burundi must register and file corporate tax returns.

How do I claim a refund of excess WHT?

A non-resident may claim a refund if WHT was deducted at the full statutory rate when a reduced treaty rate should have applied. The refund claim is submitted to OBR with supporting documents.

Does Burundi have a General Anti-Avoidance Rule?

Yes, the Burundi tax code includes general anti-avoidance provisions that allow OBR to recharacterise transactions entered into for tax avoidance purposes.

Disclaimer

This guide provides general information about Burundian cross-border taxation for the 2026 tax year. Tax laws and treaty provisions may change. Always consult with a qualified Burundian international tax advisor or the Office Burundais des Recettes for advice specific to your situation. InvestmentKit does not provide tax advice.