Corporate - Significant developments

Last reviewed - 15 July 2021

The 25% general CIT rate has been decreased to the new rate of 15% as per Finance law 2021 

The general CIT rate of 25% was decreased to 15% applicable for profits realized as from January 1st, 2021. 

The 13,5% rate has been increased to the new general rate of 15% as per Finance law 2021 

It should be noted that the finance Law 2021, abolished the tax rate of 13,5% applicable and has increased the said rate to 15% (new general CIT rate). 

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
15 200
10  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).

The threshold for Transfer Pricing obligations applicable as from January 1st, 2020 for companies having a gross revenue of TND 20 millions was increased to a revenue of TND 200 millions (VAT excluded)  

The scope of the Transfer Pricing obligations implemented by the Finance Law 2019 was reduced by the Finance Law 2021. The threshold of revenue for the definition of the companies concerned by the obligations was increased from TND 20 millions (gross revenue) to TND 200 millions (revenue excluding VAT). 

Besides, a threshold of TND 100 thousands was defined for the controlled transactions to be documented/declared. The said threshold applies by category of transactions. 

Finally, the controlled transactions to be documented/declared were limited to transactions concluded with dependent companies non resident non established in Tunisia. Transactions with dependent companies resident in Tunisia are no more concerned with the Transfer Pricing documentation/filing requirements. 

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 (still to be published).