Tunisia

The income attributable to a PE corresponds to:

• the revenues generated directly by the PE further to the exercise of its activity
• the revenues corresponding to works carried out by it, even if invoiced by the head office, and
• the revenues that would have been realised by an independent company carrying out the same business, in case the activity of the PE is provided for free.

The following charges are deductible for the purpose of the determination of the taxable results of a PE:

• All the charges incurred directly by this PE and necessary for its proper functioning. These charges have to be supported by proper documentation.
• Direct charges incurred by the head office exclusively for the PE and supported by proper documentation.
• A proportion of the indirect charges (real central administration costs) incurred by the head office. The proportion admitted for deduction is most often calculated on the basis of the turnover of the Tunisian branch against the global turnover of the head office. The deduction is limited to 10% of the Tunisian turnover in case the head office is resident of a state that did not conclude a DTT with Tunisia.