CÔTE D’IVOIRE Law and Practice Contributed by: Innocent Kouakou, Assemian Kouakou, Francky Lukanda and Lonzo Colombe, Ofori Conseils Africa LLP
3.5 Taxation of Individuals on Shares in Public Corporations Dividends received by individuals from companies listed on the BRVM are subject to IRVM at a rate of 12% pending the implementation of the general income tax reform. This rate applies to distributions made from 2025 onwards. Capital gains arising from the disposal of shares are likewise subject to IRVM at a rate of 17%. 4. Taxation of Inbound Investments 4.1 Application of Withholding Taxes Interest is subject to IRC at the standard rate of 18%. Dividends are subject to IRVM at a rate of 17%, which is reduced for dividends received from listed compa - nies. Royalties paid to local service providers are subject to BNC withholding tax at 7.5%. This rate increases to 20% where the service provider is not domiciled in Côte d’Ivoire. 4.2 Key Treaty Jurisdictions for Inbound Investment Côte d’Ivoire has entered double taxation treaties with the following countries and regional groups:
Audiovisual Communication Tax The audiovisual communication tax (XOF20,000 per hour) targets specific advertisements broadcast by non-resident channels. Finally, insurance contract tax applies to insurance premiums, with variable rates depending on the type of risk covered. 3. Corporations and Non-Corporate Businesses 3.1 Form of Closely Held Local Businesses Locally owned closely held companies generally operate in corporate form, most structured as lim - ited liability companies (SARL), simplified joint-stock companies (SAS) or unlisted public limited compa - nies (SA). They are characterised by restrictions on the free transferability of shares to control the ownership structure. These companies rely on statutory clauses (such as approval and lock-up provisions) and share - holders’ agreements to ensure stability, often moti - vated by the protection of minority shareholders. 3.2 Individual and Corporate Rates See 1.4 Applicable Corporate and Individual Tax Rates. 3.3 Restrictions on Retention of Earnings by Closely Held Corporations In Côte d’Ivoire, the IRVM applicable to profit distri - butions must be paid within three months following the date of the minutes of the shareholders’ meeting that approved the distribution, unless such decision has been officially revoked before the expiry of the deadline. 3.4 Taxation of Individuals on Shares in Closely Held Corporations There are no specific rules governing the taxation of dividends received and capital gains arising from the sale of shares in closely held companies. Gains derived from the disposal of shares in an Ivorian com - pany, as well as dividend distributions, are subject to IRVM at a rate of 17%.
• Germany; • Belgium; • Canada; • United Arab Emirates; • WAEMU member states; • ECOWAS member states; • France; • Italy; • Morocco;
• Norway; • Portugal; • United Kingdom/Northern Ireland; • Switzerland; and • Tunisia 4.3 Tax Authority Scrutiny of “Treaty Shopping” Practices
The tax administration will challenge the use of entities established in treaty jurisdictions by non-residents not
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