Corporate - Significant developments

Last reviewed - 31 July 2020

Royalty on sales of computer applications and services rendered via the Internet (the equivalent of a digital services tax [DST])

The Finance Law 2020 provides that sales of computer applications and services performed via the Internet by companies non-resident, non-established in Tunisia are subject to a royalty calculated at the rate of 3% on the revenue (excluding taxes) realised by persons and companies tax resident in Tunisia.

The said non-resident companies should declare the aforementioned turnover quarterly. The procedures for declaration and payment will be fixed by government decree.

Application of the new corporate income tax (CIT) rate of 13.5% to high added value consulting and studies services

The Finance Law 2019 has introduced a new CIT rate of 13.5% applicable for profits realised as of 1 January 2021 (to be declared in 2022) for:

  • Electronic, electrical, and mechanical industries.
  • Automotive, aeronautical, ship, railway, and component industries.
  • The wiring industry.
  • Pharmaceutical industries and medical equipment and materials.
  • The textile, clothing, leather, and footwear sectors.
  • Agro-food industries.
  • Call centres.
  • Innovation services in information technology, software development, and data processing.
  • International trade companies operating in accordance with the legislation in force.
  • Conditioning and packaging companies.
  • Logistic services companies (the list will be fixed by decree).
  • Plastic production companies.
  • Export operations carried out by service companies operating in the hydrocarbon sector established in Tunisia (sales and services provided abroad and sales and services provided in Tunisia and whose use is intended abroad).

The Finance Law 2020 added 'high added value consulting and studies services' to the list of activities subject to the rate of 13.5%. The high added value and the conditions for determining these services will be set by government decree.

The minimum CIT for companies subject to CIT at the rate of 13.5% is set at 0.1% of the local turnover (including VAT) with a ceiling of 300 Tunisian dinars (TND).

Social solidarity contribution (CSS)

The CSS is due at a rate of 1% on taxable profit with a minimum due as follows:

Companies CIT rate (%) Minimum CSS due (TND)
35 300
15, 20, or 25 200
10 or 13.5 100
0 (companies exempted from CIT or that benefit from the full deduction of profits) 200

The Finance Law 2020 increased the CSS rate for the benefits to be declared in 2020, 2021, and 2022 as follows:

  • 3% with a minimum of TND 300 for the banks, financial institutions, insurance and reinsurance companies, and the non-resident credit institutions governed by the code related to financial services destined to non-residents, for the benefits derived from services provided to resident persons and for those derived from services provided to non-residents realised as of 1 January 2021.
  • 2% with a minimum of TND 300 for other companies subject to CIT at the rate of 35% (e.g. SICAF, SICAR, debt collection companies, telecommunication operators).

Charitable contributions

The Finance Law 2020 provided that charitable contributions are deductible totally in cases where they are granted to not-for-profit organisations working for the support of people without family support and that realise their activities in accordance with the legislation in force.