Ivory Coast (Côte d'Ivoire)

WHTs are levied as follows:

• Impôt sur le revenu des valeurs mobilières (IRVM): 15% on dividends and directors’ fees.
• Impôt sur le revenue des créances (IRC): 18% on interest payments, reduced to 13.5% (individuals) and 16.5% (businesses) on bank deposit interest. The revenue realised by individuals on Treasury Bonds is exempted from tax. Foreign banks are subject to 18% tax on loan interest or 9% on equipment loans with minimum three-year terms.
• Impôt sur les benefices non commerciaux (BNC): 25% of 80% of revenues on royalties, licence fees, and management and service fees paid by Ivorian companies to foreign companies (effective rate: 20% of net amount paid). See Treaty rates below for reduced rates on royalties and management fees.
• Interest on certificates of deposit (bons de caisse): 25%.

WHT on public contracts for services

Any payment made by government bodies or public institutions to non-resident persons or companies for a contract for goods or services is subject to a 20% WHT, subject to DTTs (see Impôt sur les benefices non commerciaux above).

Resident persons or companies are not subject to this WHT, except for services (or goods) providers (individual or legal persons) registered under the standard tax regime for small companies (see below).

WHT on small-size businesses

A 2% WHT is applicable to the remunerations paid to business service providers registered under enterprising tax regime (régime de l'entreprenant) or micro-enterprise tax regime.

A 5% WHT is applicable to payments made by government bodies or public institutions for a contract for services (or goods) to a business subject to the enterprising tax regime or micro-enterprise tax regime.

A 2% WHT is applicable to payments made to service providers operating in the informal sector by persons subject to an effective tax regime. 

WHT on writers’ revenue

A 7.5% WHT applies to occasional revenue paid to individuals or companies as royalties on books, scientific studies, and artistic productions.

WHT on sums regarding intra-group transactions

In the event that the service provider does not have professional facilities in Côte d'Ivoire, the WHT on the sums due in return by the Ivorian company is now due after a period of two years without payment of the service from the entry of the sums concerned in an expense account or credited to a third-party account (2022 Financial Law).

Treaty rates

The Ivorian DTT Network:

Notes

1. Management fees (‘honoraires de gestion’) attract the 10% WHT in the United Kingdom (UK) DTT.
2. The West African Economic and Monetary Union (WAEMU) states are Benin, Burkina Faso, Côte d’Ivoire, Guinea-Bissau, Mali, Niger, Senegal, and Togo.