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Ivory CoastFiscal Guide2019March 2020KPMG.com
Country HighlightsName : Côte d’IvoireArea : 322 462 kmArea code : 225Time zone : UTCPopulation : 25,82 million (2019)Political capital : YamoussoukroEconomic capital : AbidjanNeighbouring countries : Ghana, Burkina Faso, Guinea, Liberia, MaliCurrency : XOFOfficial language : FrenchOfficial holidays (14)——————————————New year’s Day –January 1stEaster Monday – (variable)Labour day – May 1stAscencion – (Variable)Whit Monday – (variable)Independence day – August 7thAssumption – August 15thAll Saints’ Day – November 1stNational Peace Day – November 15thChristmas Day – December 25thLaïlatoulKadr – Day after the Night of DestinyAïd el Fitr – End of RamadanTabaski – Feast of sacrificeMaouloud – Birth of the Prophet 2020 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms areaffiliated with KPMG International. KPMG International provides no services to clients. No member firm has any authority to obligate or bind KPMGInternational or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any memberfirm. All rights reserved.Document Classification: KPMG Confidential1
General overviewHeadingCorporate Income Tax (CIT)The income tax in Ivory Coast, which is imposed under the General Tax Code (GTC) and applies to bothresident and non-resident companies, is divided into a series of scheduler taxes, with each particularcategory of income (or schedule) being computed and taxed according to different rules. The main categoriescomprise industrial and commercial profits, non-commercial profits, wages and salaries, income fromtransferable securities (i.e. dividends, interest), income from land and agricultural income.The regular corporate income tax rate is 25%. The minimum tax is 0.5% of turnover. For oil-producing,electricity and water-producing companies, the rate is reduced to 0.1%. The rate is reduced to 0.15% forbanks and financial companies and for insurance companies. The minimum tax may not be less than XOF3million or more than XOF35 million. New corporations are exempt from the minimum tax for their first fiscalyear.Rates :Resident companiesCorporation Tax- Resident25%- Resident telecommunication company30%Non-commercial income25%Capital gainsPart of business incomeDividends2%,10%,15%InterestBetween 1% and 18%Royalties20%Management fees20%Withholding tax (local transactions)5% & 7,5%Tax on salaries for local employees2,8%Tax on salaries for expatriate employees12% 2020 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms areaffiliated with KPMG International. KPMG International provides no services to clients. No member firm has any authority to obligate or bind KPMGInternational or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any memberfirm. All rights reserved.Document Classification: KPMG Confidential2
General overviewHeadingRates (cont.)Resident individualsProgressive:between 9.5% and 37.5%.20% for business incomePersonal Income taxNon-commercial income25%Capital gainsPart of personal st1%,5%,10%,13,5%,16,5%, 18%Employment income1.5%National contributionBetween 1,5% and 10%Non residentsIncome tax (individuals)25%Corporation tax (companies)25%, 30%Capital gains (individuals and companies)Part of personal/business incomeDividends15%*Interest18%*Non-commercial income20%Management or consultancy fees20%*Leasing equipment from non-residents20%**Final tax withheld at source (rate may vary based on the tax treaty) 2020 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms areaffiliated with KPMG International. KPMG International provides no services to clients. No member firm has any authority to obligate or bind KPMGInternational or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any memberfirm. All rights reserved.Document Classification: KPMG Confidential3
General overviewHeadingCapital gains taxCapital gains are taxed at the regular corporate rate.Rollover relief for gains is granted when the taxpayer invests a sum equal to the amount of the gain in theacquisition of a similar asset within 3 years of the sale.For shares, the relief applies only to significant long-term holdings. Subject to certain condition, capital gainsarising from a merger or partial business transfer are exempt.Transfer pricing and thin capitalization rulesIn the framework of the fight against fraud and international tax evasion launched by the OECD since 2013,the 2017 financial law, has provided for a reinforcement of its rules on international intragroup transactions.As such, the Tax Authorities requires Ivorian companies belonging to multinational groups or companies thathave control of companies located outside Côte d'Ivoire to include in their financial statementsdocumentation on intragroup transactions.There is no specific thin capitalization rule. However, interest paid by a company to its shareholders isdeductible only when the following conditions are met :—the loan is to be reimbursed within 5 years;—the company is not under a liquidation procedure during the same period;—the interest rate does not exceed the Central Bank interest rate by more than 2 percentage points;—the sums made available to the company must not exceed the amount of the share capital;—the amount of interest must not exceed 30% of the company's income;—company's share capital must have been fully paid up.Other taxesBusiness license dutyAny company, whether domestic or foreign, which carries on atrade, business or profession not included in the list of exemptionsset out in the GTC is liable to business license duty on each of itspremises.Reduced rates are provided in specific cases.Real estate tax on developed propertiesand on undeveloped propertiesTax levied on rental value of various types of properties.Rate is 15%. 2020 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms areaffiliated with KPMG International. KPMG International provides no services to clients. No member firm has any authority to obligate or bind KPMGInternational or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any memberfirm. All rights reserved.Document Classification: KPMG Confidential4
General overviewHeadingDouble tax relief and tax treatiesNo unilateral double taxation relief is granted under domestic tax law in respect of foreign taxes paid.Bilateral relief is provided under Ivorian tax treaties.Withholding tax on payments to countries with which Ivory Coast has a DTA:Type ofincomeFranceItaly SwitzerlandUKGermany BelgiumCanadWAEMUMorocco Portu Tunisia Norwaya*galDividends15%15%15%15%15%15%15%10%10%10% : West African Economic and Monetary Union (Benin, Burkina Faso, Guinea-Bissau, Mali, Niger, Senegal, Togo)*There is a bilateral tax treaty between Turkey and Ivory Coast which is not in force yet.Transaction taxesValue added tax (VAT) is levied on transactions carried out in Ivory Coast by individuals or companies who,either regularly or occasionally, purchase goods for resale or render services, other than as employees orfarming workers.VAT is levied only in respect of business activities that are carried on Ivory Coast territory.—Standard rate :18%.—Reduced rates at 9%: milk, products or wheat pasta.—Zero Rate: 0% for exportation sales.—Certain specified supplies are exempt from tax.Customs dutyAs a member state of the West African Economic and Monetary Union (WAEMU), Ivory Coast applies thecustoms rates specified in the community regulations. New rates came in force in 2015 related to theECOWAS Common External Tariff (TEC).Customs duties are levied on the customs value of imported goods at rates of 0%, 5%, 10%, 20% and 35%,depending on their classification and category 0 to 5. 2020 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms areaffiliated with KPMG International. KPMG International provides no services to clients. No member firm has any authority to obligate or bind KPMGInternational or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any memberfirm. All rights reserved.Document Classification: KPMG Confidential5
General overviewHeadingStamp and transfer dutyStamp duties are levied on documents drawn up in Ivory Coast and on those drawn up abroad where theymight be produced as evidence in legal proceedings in Ivory Coast. Fixed fees apply for paper documentsand a percentage rate for negotiable and non-negotiable instruments.Transfer duty applies to the sale of immovable property located in Ivory Coast at a rate of 6% of the priceindicated in the transfer deed.The transfer of shares and other securities is exempt from registration fees if certain conditions are met, inparticular if the transfer is executed in the form of a deed.Accounting rulesFrom an accounting perspective, like other OHADA member countries, Ivory Coast has adopted, the OHADAaccounting system (SYSCOA) provided for by the OHADA Uniform Act Relating to Accounting. Under thisAct, companies operating in Ivory Coast are required to keep their local accounts and prepare their domesticcorporate income tax returns according to the OHADA Generally Admitted Accounting Principles (GAAP).The revised SYSCOHADA was put in place in 2017 to include IFRS rules and the revised system is applicablesince January 1st, 2018.Investment informationIvory Coast is a country with strong growth with a real GDP of about 9% pursuant to preface of the NationalDevelopment Plan (2016 - 2020)Ivory Coast has an agricultural-based economy, with roughly two-thirds of the population dependent on thissector for employment. The country is the world's top cocoa producer and is also Africa's leading grower ofnatural rubber. In addition to agriculture, the Ivory Coast government is planning significant expansion in theenergy and mining sectors.The National Development Plan (2016-2020) aims to achieve emergence by 2020. 2020 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms areaffiliated with KPMG International. KPMG International provides no services to clients. No member firm has any authority to obligate or bind KPMGInternational or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any memberfirm. All rights reserved.Document Classification: KPMG Confidential6
General overviewHeadingInvestment incentivesThe 2018 new Investment Code grants investment incentives for companies, domestic or foreign, residentor non-resident, in respect of their business activities carried on in the Ivory Coast.The new investment code now classifies eligible activities into two categories:Category 1: agriculture, agro-industry, hotels, health, and higher education;Category 2: all other sectors and grants exemptions from 5 to 15 years depending on the place of theinvestment. (Zone A; B and C)The following sectors are excluded from the benefit of this code :—trade sector;—banking and financial sector;—real estate sector;—tobacco processing sector;—liberal profession.The exemptions are granted by Zone :–Zone A Abidjan district: 5 years reduced rate of 50%.–Zone B Agglomeration with a population of 60,000 or more inhabitants: 10 years. Total exemptionover the first 5 years and 50% over the last 5 years.–Zone C Agglomeration with a population of less than 60,000 inhabitants: 15 years. Total exemptionover the first 10 years and 75% over the last years.The new Code provides exemption on corporate income, business license duty, VAT and reduction oncustoms duty for investments realized under category 1.Exemptions granted for category 1 are related to the following taxes :—Corporate income tax;—Business license duty and trading license duty;—Real estate tax;—Registration duty on increase of capital.Theses exemptions are granted at the rate of 50% for zone A and B, and of 60% for zone C.For category 2, the benefits are granted in the form of a tax credit without time limit.Certain tax incentives are available to investments that must amount to at least XOF 500 million.As part of the improvement of the business environment, the State of Cote d'Ivoire has instituted a uniqueidentification number. 2020 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms areaffiliated with KPMG International. KPMG International provides no services to clients. No member firm has any authority to obligate or bind KPMGInternational or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any memberfirm. All rights reserved.Document Classification: KPMG Confidential7
General overviewHeadingOil & Gas / MiningTax incentives are granted under the Petroleum Code and the Mining Code for enterprises involved in miningand petroleum activities.These Codes provide exemption from VAT and additional taxes on imports and purchases to companiesinvolved in exploration or production of oil, gas or minerals through the means of an agreement with theGovernment.This exemption from VAT is extend to subcontractors of companies holding a service contract classified asmining or oil & gas.Housing sectorFinance Law 2004 introduced a special regime for companies approved as major investors in theconstruction sector. The benefits under this regime are granted to enable the production of inputs necessaryfor the construction of housing units or industrial facilities.Several exemptions are granted such as corporate income tax, business license duty, VAT, etc.Currency Exchange controls and ratesThe XOF is linked to the euro ( ) at a current fixed exchange rate of 1 / 655.957 FCFA. Transfers within theCFA zone are not restricted. Dividends out of revenue and capital on disinvestment maybe remitted.Communauté Financière Africaine Franc (XOF) is currently used in 8 West African States (CFA) listedbesides:—Benin,—Burkina Faso,—Cote d’Ivoire,—Guinea ce and work permitA visa is required to work in Côte d’Ivoire and is valid for a maximum of three months. An extension isrequired to stay longer.Beyond three months any non-ECOWAS national living regularly in Côte d'Ivoire for more than three monthsfrom the date of entry into Côte d'Ivoire must hold a biometric resident card.The cost of issuing the residency card is between XOF 35,000 and XOF 300,000.To get a visa, a company letter (stating a specific mission), and a confirmation of itinerary from a travel agent,must be provided. For expatriates, a local employment contract is also required. 2020 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms areaffiliated with KPMG International. KPMG International provides no services to clients. No member firm has any authority to obligate or bind KPMGInternational or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any memberfirm. All rights reserved.Document Classification: KPMG Confidential8
General overviewHeadingResidence and work permit (cont.)The amount of the costs for the employment contract visa fees is determined taking into account thenationality and duration of the applicant's employment contract into the country.For fixed-term contracts :—Non-African: one (1) month's salary per worker (basic salary extra salary);—African: half (½) of the salary per worker concerned (basic salary extra salary).For permanent employment contracts:—Non-African: one (1) month and a half of salary per worker concerned (basic salary extra salary);—African: Three-quarters (¾) of the salary, per worker concerned (basic salary extra salary).According to article 1 of the Order n 6421 of June 15th 2004 amending Order n 1437 of February 19th2004 on the regulation of the recruitment and visa fees of non-national staff employment contracts nativesfrom an ECOWAS member state do not need a visa to work in the country.Pursuant to article 5 of the social security code, it is mandatory for all employers to be registered with thenational social security fund (CNPS).In accordance with article 21 of the Social Security Code, the employer must register his employees with theNational Social Security Fund (CNPS) and pay a monthly social contribution for them.This contribution must be paid within 15 days following the previous month and the employer is required topay penalties determined by the CNPS, when contributions are not paid on time.In accordance with article 26 of the Social Security Code, the employer must submit an annual individualwage declaration each year called DISA.Since March 24th 2014, Côte d'Ivoire has adopted through Act 2014-131 a compulsory national socialprotection system against disease risk by establishing a universal health coverage (CMU).Access to universal coverage is open to all populations living in Côte d'Ivoire. 2020 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms areaffiliated with KPMG International. KPMG International provides no services to clients. No member firm has any authority to obligate or bind KPMGInternational or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any memberfirm. All rights reserved.Document Classification: KPMG Confidential9
Contacts usJean-Luc RuelleRegional Senior PartnerT: 225 20 22 57 53E: jruelle@kpmg.ciLaetitia MonnetManagerT: 225 20 22 57 53E: lmonnet@kpmg.ciStéphanie OuaffoManagerT: 225 20 22 57 53E: souaffo@kpmg.cikpmg.com/socialmediaThe information contained herein is of a general nature and is not intended to address the circumstances of anyparticular individual or entity. Although we endeavour to provide accurate and timely information, there can be noguarantee that such information is accurate as of the date it is received or that it will continue to be accurate in thefuture. No one should act on such information without appropriate professional advice after a thorough examination ofthe particular situation. 2020 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG networkof independent firms are affiliated with KPMG International. KPMG International provides no services to clients. Nomember firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties,nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved. 2020 KPMG(“KPMGtrademarksInternational”),ora Swissentity. Memberfirms ofInternational.the KPMG network of independent firms areThe KPMGnameInternationaland logo Cooperativeare registeredtrademarksof KPMGaffiliated with KPMG International. KPMG International provides no services to clients. No member firm has any authority to obligate or bind KPMGInternational or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any memberfirm. All rights reserved.Document Classification: KPMG Confidential10
banks and financial companies and for insurance companies. The minimum tax may not be less than XOF3 million or more than XOF35 million. New corporations are exempt from the minimum tax for their first fiscal year. Rates : Resident companies Corporation Tax - Resident 25% - Resident telecommunication company 30% Non-commercial income 25%
