CÔTE D’IVOIRE Trends and Developments Contributed by: Innocent Kouakou, Assemian Kouakou, Francky Lukanda and Lonzo Colombe, Ofori Conseils Africa LLP
clarified by expressly including “holders” (holders of provisional rights) so as to reduce disputes. • Tax on undeveloped property payable by the emphyteutic lessee or the holder of an emphyteutic lease is likewise reduced to 0.2% (instead of 1%), in view of the absence of full ownership and the payment of an annual charge already taxable in the hands of the lessor. At the local level, the Annex also creates an over - night stay tax for the benefit of municipalities, adjusts the tourism development tax (extension of its scope to amusement parks, event venues and businesses under the small entrepreneur regime, increase in the rate from 1.5% to 2.5% and a new allocation scheme of 50% state/50% tourism development fund) and increases the rates of contributions to local authority investment funds. The aim is to better align resources with transferred responsibilities against a backdrop of rising equipment costs. Targeted Measures to Support the Economy, Social Housing and the Environment Beyond broadening the tax base, the Annex introduc - es a number of targeted support measures that should be factored into groups’ investment and financing decisions. • Social housing and access to housing: For indi - viduals acquiring or building their first low-cost social housing unit, a tax credit equal to 5% of the price of the dwelling (capped at XOF40 million, inclusive of tax) is introduced, creditable against property tax over a five-year period. The dwelling also benefits from an exemption from land registra - tion duties, and the tax on banking transactions is exempted for loans intended to finance construc - tion of the first home. This scheme is intended to refocus public support on low-income households, with a view to reducing involuntary budgetary expenditure and better targeting beneficiaries. • Favourable clarification for mobile money: It is expressly provided that payments by mobile money are not to be treated as cash payments, such that the limitation on the deductibility of cash payments (XOF250,000) no longer applies to such flows. This clarification is strategically important for many highly digitised SMEs in terms of payments.
• Support for the agricultural sector: The right to deduct 95% of VAT borne on gas, diesel, oils and greases used as fuel for plant and civil engineer - ing machinery is extended to agricultural operators that opt to become subject to VAT and use those products for their machinery. This mechanism reduces the tax cost of energy inputs in a context where agricultural margins are particularly sensi - tive. • Environmental taxation: The special tax on certain packaging, initially extended to all plastic, metal, glass and cardboard packaging at a flat rate of XOF50/kg, is adjusted to take account of the envi - ronmental profile of the materials. Reusable glass and metal packaging, as well as corrugated card - board, are excluded from the scope, and the rate is reduced from XOF50/kg to XOF5/kg for single-use glass and metal packaging, in order to avoid what was considered disproportionate over-taxation in light of their weight and recyclability. Lastly, a preferential regime is provided for certified digital start-ups (see above), payments by special Treasury cheque are secured (with VAT only becoming chargeable when the cheque is made available, and with entitlement to reimbursement of the VAT credits thereby generated), and the regime for micro-enter - prises/the state tax for small entrepreneurs is relaxed by moving from monthly payments to four annual instalments (31 March, 30 June, 30 September, 30 November) to ease cash-flow pressure and facilitate collection. Tax Governance, Procedure and Audit: Towards a More Demanding Framework The 2026 Annex confirms a clear strengthening of tax governance, procedural rigour and the adminis - tration’s audit capacity, particularly for the benefit of local authorities and regulated sectors. The rules governing on-site tax audits are clarified: any request to postpone the first intervention must be reasoned, made in writing (by letter or electronically) at least three working days before the scheduled date and may be granted only once – and the administra - tion must respond before the initial date, with silence being deemed acceptance. The period of extension of the audit is now strictly equal to the period of suspen -
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