Tunisian-resident companies are subject to CIT in Tunisia on the basis of profits generated from permanent establishments (PEs) located in Tunisia and those attributable to Tunisia by virtue of a double tax treaty (DTT). Non-Tunisian-resident companies are subject to CIT on the basis of their Tunisian-sourced income.
PEs of non-Tunisian-resident companies are subject to CIT in the same way and under the same conditions as Tunisian-resident companies. However, certain particularities, related mainly to deductions, exist (see the Branch income section).
CIT is also due by non-resident, non-PE companies on Tunisian-sourced income through withholding taxes (WHTs).
CIT is broadly levied on the total net income resulting from the statutory financial statements of the company, duly adjusted according to the specific tax rules.
Positive/negative items of income are taxed/deducted based on the accrual basis. Income items accruing in a tax period where the above principle is not met are not allowed for tax deduction nor taxed in that tax period. Tax deduction/taxation is correspondingly deferred to the future tax periods where the principle will be met.
Income items have to be certain in their occurrence and objectively determined or determinable in their amount.
The general CIT rate is 25%. However, specific rates are foreseen for specific sectors of activity. Indeed, CIT is due at the rate of:
- 10% for:
- Companies carrying out craft activities, agricultural and fishing activities, and fitting out fishing boats.
- Trading groups of retail businesses organised as service cooperatives, governed by the general cooperation legislation.
- Service cooperatives formed between producers for the wholesale of their production.
- Consumer cooperatives governed by the general cooperation legislation.
- Profits made in the context of industrial or commercial projects benefiting from the youth employment programme or the national fund of the promotion of crafts and small businesses.
- Benefits derived from exports (except wholly exporting companies where the ten-year tax holiday period has not expired). Note that the reduced CIT rate of 10% applicable to exports will no longer apply as of 1 January 2021. As of that date, the general CIT rate will apply depending on the activity notwithstanding whether the benefits are derived from exports or from local activities.
- Support and pollution control activities.
- Companies operating in the regional development zones after the expiry of the total deduction period.
- Benefits derived from investments in the agricultural or fishing sectors at the end of the total deduction period.
- Non-resident financial service providers for profits derived from transactions realised with non-residents (for profits realised starting from 1 January 2014). Note that the reduced CIT rate of 10% applicable to profits derived from transactions realised with non-residents will no longer apply as of 1 January 2021. As of that date, the general CIT rate will apply depending on the activity notwithstanding whether the benefits are derived from exports or from local activities.
- 13.5% 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 hydrocarbons sector established in Tunisia (sales and services provided abroad and sales and services provided in Tunisia and whose use is intended abroad).
- High added value consulting and studies services. The high added value and the conditions for determining these services will be set by government decree.
- 20% for:
- Small and medium-sized entities (SMEs): SMEs are defined as trade and processing companies with total revenues (excluding taxes) not exceeding TND 1 million, and companies operating in services and non-commercial activities with total revenues (excluding taxes) not exceeding TND 500,000.
- 35% for:
- Banks (including Islamic banks) and financial institutions (leasing companies, factoring companies, investment banks).
- Offshore financial institutions governed by the code related to financial services destined to non-residents, and this only for the benefits derived from services provided to non-resident persons. Note that the reduced CIT rate of 10% applicable to profits derived from transactions realised with non-residents will no longer apply as of 1 January 2021. As of that date, the general CIT rate will apply depending on the activity notwithstanding whether the benefits are derived from exports or from local activities.
- Investment companies (SICAF and SICAR).
- Insurance, mutual insurance, and reinsurance companies.
- Takaful insurance and reinsurance companies (added by finance law 2020)
- Debt collection companies.
- Telecommunication operators.
- Profits derived from services relating to hydrocarbon sector (listed by Article 130-1 of the Hydrocarbon Code promulgated by the Law 1999-93);
- Companies rendering services to companies operating in the oil and gas field.
- Companies operating in the production and the transport of hydrocarbons and governed by particular conventions, as well as companies operating in the transfer of hydrocarbons via pipeline.
- Companies operating in the oil refining sector and the wholesale of hydrocarbon products.
- Hypermarkets (constructed area exceeding 3,000 m² or sales area exceeding 1,500 m²) as of 1 January 2020.
- Car dealers (as of 1 January 2019).
- Franchisees of a foreign brand or trademark, except for enterprises with a rate of integration equal to or greater than 30% (as of 1 January 2019).
Minimum corporate tax
A minimum corporate tax is due at the rate of 0.2% of the local turnover, including VAT, with a minimum of TND 500, in case:
- the company (subject to CIT at the rate of 25%, 20%, or 35%) realises losses, or
- the CIT due at the rate of 25%, 20%, or 35% is less than the minimum corporate tax of 0.2% of the local turnover, including VAT.
However, the minimum corporate tax is reduced to 0.1% of the gross turnover for companies subject to CIT at the rate of 10% or 13.5% and companies selling products subject to the government homologation of prices with a gross margin not exceeding 6%, with a ceiling of TND 300.
The minimum corporate tax is not due by companies benefiting from the whole exemption of profits deriving from operations (e.g. companies established in the regional development zones, companies operating in the agricultural sector) during the period of tax holidays. These latter are fixed by decree.
Local income taxes
For a description of local taxes, see Vocational training tax, Local authority tax (LAT), and Hotels tax in the Other taxes section.