Tunisia

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.

CIT rates 

CIT rates applicable are as follows (subject to exemptions and tax incentives):

• 15% as a general rate.
• 10% as a reduced rate applicable for some activities detailed below.
• 20% for companies subject to CIT at a rate of 35% and whose shares are admitted (no later than 31 December 2024) to the Tunis Stock Exchange, for five years from the year of admission.
• 35% for financial, assurance, automotive, telecom, and other important sectors, as detailed below.

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.
• 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.
• 20% for companies subject to CIT at a rate of 35% and whose shares are admitted (no later than 31 December 2024) to the Tunis Stock Exchange. The 20% rate is applicable for five years as from the year of admission.
• 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 the Finance Law for 2020).
• Debt collection companies.
• Telecommunication operators.
• Profits derived from services relating to the 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 value-added tax (VAT), with a minimum of TND 500, in case:

• the company (subject to CIT at the rate of 20%, 35%, or 15%) realises losses, or
• the CIT due at the rate of 20%, 15%, 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% and companies selling products with regulated prices having 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.