Tunisia

Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) 

On 24 January 2018, Tunisia signed the MLI. On 24 July 2023, Tunisia deposited its instrument of ratification for the MLI. The MLI entered into force on 1 November 2023:

Revision of the deadline for submission of monthly tax returns:

The Finance Law for 2024 has revised the deadline for filing monthly tax returns from day 28 to day 20 of the following month for companies that file their returns electronically.

Four years exemption from income tax for newly created entities in 2024 and 2025:

The Finance Law for 2024 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 CITable 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.

Establishment of a conjunctural contribution for the benefit of the state budget for the fiscal years (FYs) 2024 and 2025

The Finance Law for 2024 instituted a conjunctural contribution for the benefit of the state budget for the years 2024 and 2025. Such contribution is due at the rate of 4% of FY23 and FY24 taxable income (with a minimum of 10,000 Tunisian dinars [TND]) by banks, financial establishments (leasing companies, factoring companies, investment banks), and insurance and reinsurance companies.

Increase of customs duties due for the import of solar panels

The Finance Law for 2024 has increased the customs duties applicable to the import operations of solar panels from 10% to 30%.

Encouragement of companies to finance research and development (R&D) expenses

The Finance Law for 2022 provides an additional deduction of 50% of R&D expenses incurred by companies under agreements concluded with public scientific research establishments, public education and research establishments, or other public establishments authorised for research under the laws and regulations in force.

The following conditions apply:

• The company's contribution to the total R&D expenses covered by the agreement is not less than 10% of the total amount of these expenses.
• The additional deduction does not exceed TND 200,000 per year.

The Finance Law for 2023 increased the cap of TND 200,000 per year to TND 400,000 per year for R&D expenses incurred in the context of the green, blue, circular, and sustainable development economy.

Also, the Finance Law for 2023 provides that companies benefit from an additional deduction of 50% of innovation expenses, capped at TND 400,000 per year. The deductibility conditions of such a deduction will be fixed by decree.

Considering that the additional deduction represents a fictitious charge, which does not correspond to any current expense, it should be recorded in an extra-accounting manner through a deduction from the accounting result.