CÔTE D’IVOIRE Law and Practice Contributed by: Innocent Kouakou, Assemian Kouakou, Francky Lukanda and Lonzo Colombe, Ofori Conseils Africa LLP
1.4 Applicable Corporate and Individual Tax Rates The corporate and business income tax rates are as follows: • 25% for individuals and legal entities; and • 30% for companies operating in the telecommuni - cations, information technology and communica - tion sectors. The tax liability thus calculated must be compared with the minimum flat-rate tax ( impôt minimum for- faitaire ), and the higher of the two amounts shall be retained for tax filing purposes. As a reminder, the minimum tax is payable in the fol - lowing cases: • the income tax amount for the fiscal year is lower than the minimum flat-rate tax due for said year; or • the cumulative amount of taxes and duties owed for the fiscal year (excluding third-party taxes) is lower than the maximum flat-rate tax amount applicable to micro-enterprises, determined based on the upper turnover threshold of the micro-enter - prise tax regime. The minimum tax for a given accounting period is equal to 0.5% of the total turnover, inclusive of all taxes ( toutes taxes comprises – TTC). The minimum assessment is set at XOF3 million, while the maximum is capped at XOF35 million. Taxable profit is defined as the net profit derived from the overall results of all operations of any kind car - ried out by the business, including the disposal of any assets, whether during or at the end of operations. In other words, net profit is determined by aggregating all income and expenses arising from any transactions conducted by the company. It consists of the difference between the net asset values at the closing and opening of the period whose results serve as the tax base, adjusted by deducting 2. Corporate Tax Regime 2.1 Taxable Profits
additional capital contributions and adding any with - drawals made during this period by the owner or the partners. The tax result may be a profit, a loss or nil. In the event of a nil result or a tax loss, the taxpayer must pay a minimum flat-rate tax ( impôt minimum forfaitaire ) instead of the corporate and business income tax. The business income tax or the minimum tax deter - mined for a given fiscal year is payable in three equal instalments during the following year, in April, June and September. 2.2 Technology Investments In Côte d’Ivoire, the main tax incentive dedicated to the technology sector remains the free zone regime. However, outside this specific framework, ordinary law companies may benefit from several tax meas - ures designed to encourage technological investment. The first mechanism is the tax credit for the acquisition of patents and manufacturing processes. It targets industrial SMEs and information and communication technology (ICT) companies with an annual turnover below XOF1 billion. The tax credit amounts to 30% of the acquisition cost of new patents or processes, sub - ject to conditions including retention of the patent for at least five years, membership in an approved man - agement centre or engagement of a certified account - ant – and, for technology companies, certification from the ministry in charge of new technologies. The credit is directly offset against corporate income tax ( bénéfices industriels et commerciaux – BIC). The second mechanism is the research, development and innovation (RDI) tax credit (Article 114 bis of the General Tax Code ( Code General des Impôts – CGI), available to all companies. It represents 50% of quali - fying investment, provided that at least 15% of total expenses are exclusively allocated to R&D activities. In addition, the 2026 Finance Law introduces a three- year preferential regime for certified digital start-ups, including exemptions from BIC and certain financial taxes.
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