CÔTE D’IVOIRE Law and Practice Contributed by: Innocent Kouakou, Assemian Kouakou, Francky Lukanda and Lonzo Colombe, Ofori Conseils Africa LLP
Property Wealth Tax Since January 2026, legal entities have been subject to property wealth tax on real estate used for business purposes (rate: 13% of market value). Registration Duties Registration constitutes both a tax and a legal formal - ity. The rates are as follows: • share capital – 0.3% (up to XOF5 billion) or 0.1% (above that threshold); and • commercial leases – 2.5% of annual rent for fixed- term leases and 10% of capital value (20 times the rent) for indefinite-term leases. IRVM This applies to dividends, share income and direc - tors’ fees: • standard rate – 15% (17% for individuals); • reduced rates – 10% for companies listed on the regional stock exchange ( Bourse Régionale des Valeurs Mobilières – BRVM) and 2% for certain bonds; and • special rule – for head offices located outside Côte d’Ivoire, the taxable base is deemed to be 50% of taxable profit. Tax on Income From Claims (IRC) This applies to interest on loans and deposits. The standard rate is 18%, and there are reduced rates for bank accounts depending on maturity (from 1% to 16.5% for companies). The Special Equipment Tax (TSE) Taxe sur le matériel spécial (TSE) applies to compa - nies under the real tax regime with annual turnover exceeding XOF200 million, at a rate of 0.1% of net turnover. The Banking Operations Tax (TOB) Taxe sur les opérations bancaires (TOB) applies to banking and financial activities at 10%, reduced to 5% for certain SME and microinsurance credits. Advertising Tax A 3% advertising tax applies to advertising messages.
• Full exemption may apply where the holding company’s portfolio consists of at least 60% of participations in companies established in WAEMU member states. If the qualifying conditions are not met, capital gains are taxed under ordinary corporate tax rules. 2.8 Other Taxes on Transactions Ivorian VAT applies to supplies of goods and services performed for consideration, excluding salaried and agricultural activities. It also covers imports and spe - cific transactions. VAT is calculated on the net-of-tax amount at a standard rate of 18% or a reduced rate The bénéfices non commerciaux (BNC) tax applies to income derived from intellectual property (IP; copy - rights, patents, trade marks, secret processes) and service fees. The standard rate (in the absence of a double tax trea - ty) is 20% for service providers without a professional establishment in Côte d’Ivoire and 7.5% for local sup - pliers. The tax is withheld at source by the company paying for the services. of 9% for certain products. 2.9 Other Notable Taxes Non-Commercial Profits Tax (BNC) Business Licence Tax (Contribution des Patentes) This tax is payable by any person carrying out a pro - fessional activity and comprises two components: • turnover-based duty – 0.5% of the previous year’s turnover (minimum XOF300,000, capped accord - ing to brackets ranging from XOF350,000 to XOF3 million); and • rental value duty – 18.5% of the rental value of business premises (16% outside municipal areas). Payroll Taxes and Related Contributions Employers act as withholding agents for payroll tax ( impôt sur les traitements et salaires – ITS) and are liable for their own contributions. The overall effective rate is 2.8% for local employees and 12% for expa - triate employees. These rates include the national contribution (1.5%), apprenticeship tax (0.5%) and vocational training levy (1.5%), after a 20% allowance.
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