CÔTE D’IVOIRE Trends and Developments Contributed by: Innocent Kouakou, Assemian Kouakou, Francky Lukanda and Lonzo Colombe, Ofori Conseils Africa LLP
• For online transport-matching platforms, the 4% withholding tax on the income of vehicle owners is abolished and replaced by a return to the transport licence tax, with registration or continued list - ing of a vehicle on the platform being conditional upon proof that this licence tax has been paid. In the event of non-compliance, the platform must deactivate the vehicle or becomes jointly liable for payment. • A preferential regime is introduced for certified digi - tal start-ups operating outside the information and communications technology (ICT) free zone, with exemption from profits tax for those subject to the real tax regime; exemption from the lump-sum con - tribution for those under the micro regime or the state tax for small entrepreneurs; and exemption from the taxes on banking transactions and income from receivables for three years from certification. This regime gives tax effect to the 2023 law on the promotion of digital start-ups and forms part of the strategy to support technological innovation. • Obligations relating to the identification of benefi - cial owners are significantly strengthened: the up- to-date identification form must now be attached mandatorily to annual financial statements, failing which a fine of XOF1 million applies, increased by XOF100,000 for each month of delay. The aim is to give the authorities an up-to-date view of chains of control, in the context of combatting base erosion and money laundering. • Non-profit entities (associations, professional bodies and structures managing donor-funded projects) are made subject to a structured obli - gation to file their financial statements electroni - cally, in accordance with the Organisation pour l’Harmonisation en Afrique du Droit des Affaires (OHADA; Organisation for the Harmonization of Business Law in Africa)/ Système Comptable des Entités à But Non Lucratif (SYCEBNL; Accounting System for Non-Profit Entities) framework, no later than 30 May, with the first deadline being 30 May 2027 for the financial year ending on 31 Decem - ber 2026. Other civil society organisations must at a minimum file a simplified annual statement of resources and expenditure, unless their resources remain below XOF50 million.
Lastly, a mechanism for advance pricing agreements (APAs) in transfer pricing matters is formally intro - duced, following on from the Medium-Term Revenue Mobilisation Strategy and Economic Community of West African States (ECOWAS) recommendations. This mechanism enables the taxpayer to secure, for a renewable period of three to five years, methods for determining arm’s length prices for international intra-group transactions, subject to the possibility of revocation where there is an imbalance to the detri - ment of the Treasury. Reforms of Property and Territorial Taxation: Adjustments and Acceptability Following the major reforms of 2024–25, the 2026 Annex recalibrates property taxation so as to recon - cile yield with social acceptability, while preserving the principle of reference to market value. • The rate of tax on landed property applicable to built properties owned by companies and legal persons, as well as to unfinished buildings record - ed as assets, is reduced from 15% to 13% of the base determined by reference to market value. For undeveloped properties, the 1% rate is main - tained, but the increase in tax payable is capped at between 10% (minimum) and 25% (maximum) compared with 2024 tax in order to lessen the impact. • Tax on non-built and non-income-producing prop - erties owned by the autonomous port of San Pedro is reduced from 0.75% to 0.40%, in order to take account of the specific features of this strategic operator. • For taxpayers who received significantly increased 2025 tax assessments, a mechanism of tax credit and remission is provided: amounts exceeding 100% of 2024 tax constitute either a credit off - settable against 2026–27 tax (if the taxpayer has already paid the whole of the 2025 amount) or a remission conditional on regular payment of 2024 liabilities and a minimum 2025 payment equal to 100% of the 2024 tax. • The road maintenance, hygiene and sanitation tax, based on market value, is fixed at 0.2%, with the same cap on variation (10% to 25% compared with 2024), and the category of liable persons is
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