Ivory Coast (Côte d'Ivoire)
In Côte d’Ivoire, companies are considered resident in tax jurisdictions where they have a registered fixed establishment (e.g. subsidiaries, branches, representative offices).
Permanent establishment (PE)
A non-resident is considered as having a PE in Côte d’Ivoire when its activities involve a comprehensive commercial cycle in Côte d’Ivoire or when it operates through a dependent agent in Côte d’Ivoire.
According to DTTs, a non-resident is considered as having a PE in Côte d’Ivoire when it has a registered establishment, including a subsidiary, a branch, a representative office, a mine or an oil well, a building site, a manufacture plant, or a trading establishment. Sometimes, a time threshold of six months is considered.