Ivory Coast (Côte d'Ivoire)

Group taxation is not permitted in Côte d’Ivoire.

Transfer pricing

Profits directly or indirectly transferred to related non-resident companies are disallowed from the income tax basis.

The tax administration may inquire on transfer pricing when local subsidiaries having most of their transactions with non-resident group companies record losses.

A transfer pricing report on group transactions must be filed together with annual financial statements, and the description of the method used by the taxpayer to determine its transfer prices must be expressly specified.

Since the 2023 Tax Annex law entered into force, the obligation to produce the master file and the local file is charged to Ivorian companies carrying out international intra-group transactions and coming under the management of large and medium-sized enterprises.

The master file-local file documentation must be produced and made available to the tax authorities on the date of the start of the verification of accounts, namely the date of the first intervention on place as shown on the tax notice.

Country-by-country (CbC) reporting

A CbC report must be filed when group consolidated turnover of XOF 250 billion is met.

Thin capitalisation

The deduction of the interest of loans granted on top of the share capital by related parties is subject to restrictions (see Interest expenses in the Deductions section).

When, because of losses, the equity of the company is less than 50% of the share capital, the company must be recapitalised in the two following years, unless the company is dissolved.

Controlled foreign companies (CFCs)

There are no CFC rules in Côte d’Ivoire.