http://www.pwc.com/globalmobility

Global Mobility Services:

Taxation of International Assignees - Côte d’Ivoire

Taxation issues &

related matters for

employers &

employees 2015

Last updated: June 2016

This document was not intended or written to be used, and it cannot be used for the purpose of avoiding tax penalties that may be imposed on the taxpayer.

Global Mobility Country Guide (Folio) 3

Country Côte d’Ivoire

Introduction: 4

Step 1: Income tax summary 5

Step 2: Rates of tax 11

Appendix A: Contacts and offices 12

Additional Country Folios can be located at the following website:

Global Mobility Country Guides.

4 People and Organisation

Introduction:

PwC is the world's leading provider

of professional services. The People

and Organisation group works

together with its clients to find

solutions for the challenges they

encounter when transferring people

from one country to another.

This summary is intended to inform

foreign nationals and their

employers about high level

tax, social security and

immigration issues.

This guide is not exhaustive and

cannot be regarded as a substitute

for professional advice addressing

individual circumstances.

Nevertheless, answers will be found

to most of the questions raised by

an expatriate or his/her employer.

More detailed advice should be

sought before any specific decisions

are made about these issues.

More information can be obtained

from our offices specializing in

People and Organisation, Global

Mobility.

Global Mobility Country Guide (Folio) 5

Step 1: Income tax summary

Question Answer

Basic information

1 The date of the tax year end The Ivory Coast tax year runs from 1 January to 31 December.

2 Types of income that are liable to tax Incomes liable to tax are employment income. They include all employment benefits provided by the Employer whether in cash or in kind in addition to salary.

3 How are residents and non residents treated differently for tax purposes?

In the absence of a DTA, a non resident employee will be taxable in Ivory Coast like a resident employee without considering the duration of stay of the employee in Ivory Coast (from day one). Conversely, in presence of a DTA, the remuneration of the employee is not taxable in Ivory Coast if the said employee spends in Ivory Coast a period, or periods, less than 183 days during a fiscal year.

However, without exceeding the period of 183 days, the employee will be taxable in Ivory Coast if his salary is:

paid by (or on behalf of) an employer located in Ivory Coast;

recharged to an employer located in Ivory Coast.

4 Do spouses file tax returns jointly or as individuals?

Married taxpayers file tax returns as individuals.

5 Method of determining domestic tax residence

An individual is deemed to have his tax residence in Côte d’ Ivoire if:

He has a home as an owner or tenant (more than one year lease contract) in Côte d’Ivoire.

He has no home in Côte d’Ivoire, but Côte d’Ivoire is the place of his principal stay.

Subject to international conventions, the tax is payable by any person having his residence in Côte d’ Ivoire.

6 6 People and OrganisationHuman Resources Services

Question Answer

6 Provide some details of the exchange controls in this jurisdiction

Foreign financial relationships of entities operating in Côte d’Ivoire are governed by the Regulation n°R09/2010/CM/UEMOA applicable to all member states of West African Economic and Monetary Union.

This regulation authorize in general free payment (or transfer) abroad of (…) expatriate’s personnel income, foreign insurance premium, foreign social security contribution, deriving from an employment contract performed in Ivory Coast.

Tax rates, allowances and credits

7 Income tax rate The personal income tax includes 3 separate taxes:

General Income Tax

National Contribution

Salary Tax

General Income Tax

General income tax ("IGR") is calculated using a "taxable amount" divided by the number of dependents and is subject to marginal tax rates that vary up to 60% (See the below table).

The "taxable amount" is calculated by deducting the following from the individual's gross income:

– A salary tax at a rate of 1.5% (on 20% of the individual's gross income); less

– A national contribution which rates range from 0% to 10% (on 80% of gross income); less

– A special 15% deduction.

Salary Tax

Salary tax is calculated using the rate of 1.5% of the taxable revenue after a deduction of 20%.

Global Mobility Country Guide (Folio) 7

Question Answer

National Contributions

National Contributions rates vary according to the range of salary of the employee (See the below table N°1).

Taxable Revenue in CFAF Rate

Less than 600,000 0%

Between 600,000 & 1,560,000 1.5%

Between 1,560,000& 2,400,000 5%

More than 2,400,000 10%

8 Income tax allowance amount N/A

9 Capital gains tax allowance amount Resident employees are taxed on their gains other than employment revenues.

10 Rate of capital gains tax In calculating tax on income other than wages salaries, the rates applicable to taxable annual net income are set in a progressive way, for every income determined as follows:

1000 & 2,200 000 2%

2,200 001 & 3,600 000 10%

3,600 001 & 5,200 000 15%

5,200 001 & 7,200 000 20%

7,200 001 & 9600 000 24%

9,600 001 & 12600 000 26%

12,600 000 & 20 000 000 29%

20 000 001 & 30 000 000 32%

30 0000 001 & 40 000 000 34%

40 000 0001 & 50 000 000 35%

Up to 50 000 001 36%

11 Rate of tax on interest The standard rate is 18%.

12 Rate of tax on dividends The standard rate is 15%.

8 8 People and OrganisationHuman Resources Services

Question Answer

13 Rate of employer social security The rate of the employer social security are the following:

Family allowance at 5,75% with a monthly ceiling up to 70 000 FCFA;

Work injuries from 2% up to 5% with a monthly ceiling 70 000 FCFA;

Retirement 7.7% with a ceiling 1,647 315 FCFA.

14 Rate of employee social security The employee contributes only to his retirement at the rate of 6.3%.

15 What types of income are exempt from tax/deductible from taxable income?

Employer’s social security contributions

Employer’s social security contributions paid to complementary retirement or contingency constitute a taxable cash benefit. This benefit is exempt from tax up to the following limits: XOF 300,000 per month and 10% of the gross taxable remuneration of the employee. As a consequence, the employer’s contributions that exceed either of the limits are taxable.

Compulsory social security payments paid in the Ivory Coast to the CNPS are not affected by the limit.

Transport premiums

Transport premiums are exempt up to XOF 25,000 per month. Expenses covered by this indemnity are the general expenses incurred by the employee from his home to his place of work.

Professional indemnities

Indemnities to cover costs inherent in the job or work are exempt up to a limit of 10% of gross taxable remuneration of the employee including the indemnity itself. These indemnities may correspond only to displacements linked to the exercise of the job, or corresponding to representation charges. Justification of the use of such indemnities may be required.

Global Mobility Country Guide (Folio) 9

Question Answer

Before arriving in the country

16 What must an individual do in order to be able to work in the country ie obtain a work permit, intra company transfer visa, critical skills visa

The hiring of any non-Ivorian employee by an entity located in Côte d’ Ivoire is subject to the application for a work permit, which is obtained through an application made at the Youth Employment Agency, it can also be done once the assignee is in the country.

17 What conditions must be met to be eligible to have a work permit

The visa is granted upon the filing of an application form and the provision of the following documents:

An official form available to the Youth Employment Agency filed and signed by both employer and employee;

A police record of the employee;

A curriculum vitae of the employee;

A medical examination certificate of the employee;

A pay slip of the employee;

A certificate of employment and a copy of the employee's degree.

The administrative fees for the employment contract visa procedure are as follows:

Limited term contracts: The cost is half month salary for African employees and one month salary for non-African employees.

Unlimited term contracts: the cost is one and half month salary for non-African employees and ¾ salary (75% salary) for African employees.

The employment contract visa procedure generally lasts about two weeks.

What is the maximum period a work permit will be issued for

The maximum period a work permit will be issued for is one year.

19 Can a work permit be renewed The work permit should be renewed each year at its anniversary date.

20 What would be the immigration requirements for a short term business visitor

The visitor should request a business entry visa at the Ivory Coast embassy in his home country.

21 At what point/type of activity would trigger a tax liability in the country

Please see our answer in point n°3 above.

10 10 People and OrganisationHuman Resources Services

Question Answer

During the assignment

22 Does an individual need to register as a taxpayer

No. Employee personal income taxes are withheld and paid by the employer.

23 Timeline and process for registering as a taxpayer

N/A

24 Are provisional taxes required? N/A

25 If yes, on which dates? N/A

26 If yes, what are the penalties for non compliance?

N/A

27 Important dates to remember during the tax year

N/A

At the end of the tax year

28 Tax return filing deadline N/A. Tax return filing is the obligation of the employer. The personal income taxes are due on the 10th of the month following the salary payment.

29 Penalty for late filing N/A from employee perspective.

30 Tax payment deadline N/A from employee perspective.

31 Penalty for late payment N/A from employee perspective.

At the end of an assignment

32 The process and actions required before leaving the country

The assignee leaving Côte d’ Ivoire must report his departure the tax authority in order to be issued a tax clearance certificate.

Other comments None

Global Mobility Country Guide (Folio) 11

Step 2: Rates of tax

Personal income tax rates for 2015 (specify currency)

Income Received (CFAF) Tax rate

0 to 300,000 0%

300,001 to 525,000 10%

526,000 to 900,000 15%

901,000 to 1,350,000 20%

1,351,000 to 2,250,000 25%

2,251,000 to 3,750,000 35%

3, 751,000 to 7, 500,000 45%

More than 7, 500,000 60%

12 People and Organisation

Appendix: Contacts and offices

Contacts

Dominique Taty

Partner

Tel: +225 20 31 54 67

Email: d.taty@ci.pwc.com

© 2016 PricewaterhouseCoopers LLP. All rights reserved. "PricewaterhouseCoopers" refers to PricewaterhouseCoopers LLP (a Delaware limited liability partnership) or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. “PricewaterhouseCoopers” and “PwC” may also refer to one or more member firms of the network of member firms of PricewaterhouseCoopers International Limited (PwCIL), each of which is a separate legal entity. PricewaterhouseCoopers does not act as agent of PwCIL or any other member firm nor can it control the exercise of another member firm’s professional judgement or bind another firm or PwCIL in any way.