CÔTE D’IVOIRE Trends and Developments Contributed by: Innocent Kouakou, Assemian Kouakou, Francky Lukanda and Lonzo Colombe, Ofori Conseils Africa LLP
The 2026 Finance Annex forms part of a path towards accelerated modernisation of the Ivorian tax system, with a clearly stated dual objective: to strengthen rev - enue mobilisation on a lasting basis while safeguard - ing the framework for business development. It comes at a time of strong economic resilience (with growth expected to reach 6.7% in 2026), but also of budget - ary pressures linked to the international environment and the financing needs of the new 2026–30 National Development Plan (NDP). The structure of the Annex is organised around six areas: • broadening the tax base and combatting tax eva - sion; • targeted measures in favour of social housing; • development of environmental taxation; • selective support for the economy (particularly the digital and agricultural sectors); • rationalisation and simplification of the system; and • technical adjustments and alignment with regional and international standards. For businesses, it therefore combines increases in, or the creation of, levies, stricter transparency obliga - tions and a number of targeted preferential regimes (start-ups, housing, agriculture), making an immediate update of tax strategies necessary. Strengthening resource mobilisation and combatting base erosion The first pillar of the Annex rests on a targeted broad - ening of the tax base and better capture of income that has so far been little taxed or poorly taxed, par - ticularly in the digital economy and certain high value- added sectors. • Withholding tax on non-commercial profits is extended to all self-employed participants in radio, television and film productions, in order to secure taxation of a fast-growing sector that remains partly informal. • Factoring transactions are expressly made subject to VAT, putting an end to differing interpretations linked to the banking status of factors and reduc - ing the risk of disputes.
• A large number of VAT exemptions are being streamlined: transactions involving jute and sisal fibres, feed for livestock and poultry, related inputs and packaging, as well as certain fertiliser inputs are now subject to the standard 18% rate. This policy of “pruning” tax exemptions, already begun in 2025, is being continued in order to align nation - al practice with community requirements with respect to controlling tax expenditure. • The excise duty base on cigarettes imported from states not linked by a customs union is increased from XOF20,000 to XOF25,000 per 1,000 cigarettes (that is, from XOF400 to XOF500 per pack of 20), in order to restore what is regarded as fairer competi - tion with local production. At the same time, taxation relating to the public domain and local authorities is being redeployed to better reflect the real value of assets and finance infra - structure: charges for occupation of the public domain are now based on market value, with a share allocated to the ministry responsible for roads and penalties for failure to renew or unlawful occupation being signifi - cantly increased. Municipalities are to benefit from a new local overnight stay tax, payable by customers of hotels and furnished residences, with a tariff scale differentiated according to classification or the size of the local authority. Major Innovations in Digital Taxation and Transparency The 2026 Annex marks a turning point on two struc - tural fronts: taxation of the digital economy (platforms and start-ups) and strengthening the legal and tax transparency of entities. • A specific tax on the profits of foreign e-commerce platforms with no business establishment in Côte d’Ivoire is introduced, based on the concepts of “significant economic presence” and “virtual permanent establishment”. It becomes payable once turnover generated remotely in Côte d’Ivoire reaches XOF50 million, with a rate of 30% applied to a deemed profit of 10% of the relevant turnover, and with the possibility of crediting any withhold - ing tax already applied to those services in order to avoid domestic double taxation.
97 CHAMBERS.COM
Powered by FlippingBook