INTRAGROUP INTERNATIONAL TRANSACTIONS

The new measures adopted by the 2017 Tax Annex in Article 15, are making major changes to international taxation and combating tax evasion.

• When it comes to filing statements Financial

The Administration tax burden now requires companies that are under dependence or who have control of companies located outside Côte d’Ivoire, in the filing their financial statements, to attach to them, a documentation containing:

1. A general description of the legal and operational structures of the group of companies associated with the identification and geographical location of the associated companies engaged in intra-group transactions over the past Exercise
2. A general presentation of the transactions with companies associated with the past including the nature and amount of transactions, as well as the nature and amount of transactions The identity and geographical location of the group’s companies Involved.

The no production of this documentation or the production of documentation incomplete is sanctioned by the rejection as deductible charges, sums of money paid for transactions with associated companies.

• In terms of deductibility amounts paid abroad

The Administration tax, now caps the deductibility of money paid abroad to the 50 of the gross amount of transactions or transfers made with individuals located or established in a non-cooperative country or territory.

Are considered non-cooperative or tax-regulated countries or territories countries or territories on the “blacklist of non-non-privileged countries” Co-operative organization of the Organisation for Economic Co-operation and Development (OECD) and having not reached an agreement with Côte d’Ivoire, no agreement reciprocal exchange of information for tax purposes.

• In terms of tax on securities income

The Code General of Taxes provides in its new article 183 bis that the rates set at:

1. 10 for dividends regularly paid by companies listed on the stock exchange Regional Securities;
2. 2 for all products, lots and repayment premiums paid to bondholders issued in Ivory coast and refundable in at least five years;

are increased 25 when the taxable sums are paid to a natural person or person established in a non-cooperative country or territory or in a non-cooperative country or territory. preferred taxation.

• In terms of tax on receivables income

The Code General of Taxes provides in its new article 193 bis that the various income tax rates on receivables are increased by 25 , when taxable sums are paid to a person or corporation located or established in a non-cooperative country or territory or with preferential taxation.

• When it comes to verifying Accounting

Now The Tax Office has, in accounting audits, the right to conduct joint audits with tax administrations in other countries. As part of these audits the Tax Office may be assisted by an expert.