Tunisia

Tunisian-resident companies are subject to CIT in Tunisia on the basis of profits generated from permanent establishments (PEs) located in Tunisia and those attributable to Tunisia by virtue of a double tax treaty (DTT). Non-Tunisian-resident companies are subject to CIT on the basis of their Tunisian-sourced income.

PEs of non-Tunisian-resident companies are subject to CIT in the same way and under the same conditions as Tunisian-resident companies. However, certain particularities, related mainly to deductions, exist (see the Branch income section).

CIT is also due by non-resident, non-PE companies on Tunisian-sourced income through withholding taxes (WHTs).

CIT is broadly levied on the total net income resulting from the statutory financial statements of the company, duly adjusted according to the specific tax rules.

Positive/negative items of income are taxed/deducted based on the accrual basis. Income items accruing in a tax period where the above principle is not met are not allowed for tax deduction nor taxed in that tax period. Tax deduction/taxation is correspondingly deferred to the future tax periods where the principle will be met.

Income items have to be certain in their occurrence and objectively determined or determinable in their amount.

It should be noted that, on 24 January 2018, Tunisia signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). 

On 24 July 2023, Tunisia deposited its instrument of ratification for the MLI. The MLI entered into force on 1 November 2023:

CIT rates 

The Finance Law 2025 has revised corporate tax rates. The general corporate tax rate has increased from 15% to 20%. Activities subject to the 10% rate remain unchanged. Activities subject to the 35% rate remain unchanged, except for banks, financial institutions (including non-resident institutions), and insurance and reinsurance establishments that are subject to a new rate of 40% for revenue realized as from 1^st January 2024.

CIT rates applicable are as follows (subject to exemptions and tax incentives):

• 20% as a general rate.
• 10% as a reduced rate applicable for some activities detailed below.
• 20% for companies subject to CIT at a rate of 35% or 40% and whose shares are admitted (no later than 31 December 2024) to the Tunis Stock Exchange, for five years from the year of admission.
• 35% For payment institutions, automotive, telecom, and other important sectors, as detailed below .
• 40% for banks (including Islamic banks) and financial institutions (leasing companies, factoring companies, merchant banks), including non-resident banks and financial institutions, insurance and reinsurance companies.

Indeed, CIT is due at the rate of:

• 10% for:  
• Companies carrying out craft activities, agricultural and fishing activities, and fitting out fishing boats.
• Trading groups of retail businesses organised as service cooperatives, governed by the general cooperation legislation.
• Service cooperatives formed between producers for the wholesale of their production.
• Consumer cooperatives governed by the general cooperation legislation.
• Profits made in the context of industrial or commercial projects benefiting from the youth employment programme or the national fund of the promotion of crafts and small businesses.
• Support and pollution control activities.
• Companies operating in the regional development zones after the expiry of the total deduction period.
• Benefits derived from investments in the agricultural or fishing sectors at the end of the total deduction period.
• 20% for companies subject to CIT at a rate of 35% or 40% and whose shares are admitted (no later than 31 December 2024) to the Tunis Stock Exchange. The 20% rate is applicable for five years as from the year of admission.
• 35% for:
• Payment institutions as stipulated by Law No. 2016-48 dated July 11, 2016
• investment companies (SICAF and SICAR).
• Debt collection companies.
• Telecommunication operators.
• Profits derived from services relating to the hydrocarbon sector (listed by Article 130-1 of the Hydrocarbon Code promulgated by the Law 1999-93).
• Companies rendering services to companies operating in the oil and gas field.
• Companies operating in the production and the transport of hydrocarbons and governed by particular conventions, as well as companies operating in the transfer of hydrocarbons via pipeline.
• Companies operating in the oil refining sector and the wholesale of hydrocarbon products.
• Hypermarkets (constructed area exceeding 3,000 m² or sales area exceeding 1,500 m²) as of 1 January 2020.
• Car dealers (as of 1 January 2019).
• Franchisees of a foreign brand or trademark, except for enterprises with a rate of integration equal to or greater than 30% (as of 1 January 2019).
• 40% for:
• Banks, including Islamic banks and financial institutions (leasing companies, factoring companies, and investment banks), except for payment institutions.
• Non-resident banks and financial institutions according to the foreign exchange regulation,
• Insurance and reinsurance companies, including mutual insurance, Takaful insurance and reinsurance companies, as well as the adherents' fund (Law No. 47-2014 dated July 24, 2014).

It should be noted that The FY24 Finance Law provides a four-years corporate income tax (CIT) and personal income tax (PIT) exemption to newly created enterprises that filed an investment declaration in 2024 or 2025. The first-year exemption starts from the effective start date activity and ends on 31 December of the same year. Such enterprises should enter into activity within two years from the investment declaration obtention date and should keep their accounts according to the Tunisian accounting standards.        

Companies located in Regional Development areas that are entitled to the deduction from CIT income of profits derived from investments over five or ten years as from the activity effective start date can benefit from the four-years exemption period before the five- or ten-years full deduction period.

Some blacklist activities are excluded from the said PIT/CIT exemption, including companies operating in the financial and energy sectors, with the exception of renewable energies, mines, real estate development, on-site consumption, trade and transport, operators telecommunication, companies created by persons who have carried out an activity of the same nature as that carried out by new created company, as partners or managers, or having a first-degree relative (spouse or children) with persons having said status in another company carrying out an activity of the same nature.

Minimum corporate tax

A minimum corporate tax is due at the rate of 0.2% of the local turnover, including value-added tax (VAT), with a minimum of TND 500, in case:

• the company (subject to CIT at the rate of 20%, 35%, or 40%) realises losses, or
• the CIT due at the rate of 20%, 15%, or 35% or 40% is less than the minimum corporate tax of 0.2% of the local turnover, including VAT.

However, the minimum corporate tax is reduced to 0.1% of the gross turnover for companies subject to CIT at the rate of 10% and companies selling products with regulated prices having a gross margin not exceeding 6%, with a ceiling of TND 300.

The minimum corporate tax is not due by companies benefiting from the whole exemption of profits deriving from operations (e.g. companies established in the regional development zones, companies operating in the agricultural sector) during the period of tax holidays. These latter are fixed by decree.

Local income taxes

For a description of local taxes, see Vocational training tax, Local authority tax (LAT), and Hotels tax in the Other taxes section.