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Finance Act 2024

Tax measures
CONTENT
1.PERSONAL INCOME TAX AND CORPORATE INCOME TAX P 01

2.TAX INCENTIVES P 03

3. VAT P 09

4. OTHER TAXES P 13

5. TAX OBLIGATIONS & PROCEDURES P 22

6. AMNESTY P 28

7. CUSTOMS P 32

8.FINANCING MEASURES P 35

9. SUPPORT MEASURES FOR PUBLIC ENTERPRISES P 37

10. OTHER MEASURES P 39

| Finance Act 2024 Tax measures


Finance Act 2024 Tax measures
1.
PERSONAL INCOME TAX AND
CORPORATE INCOME TAX
1.1 Deduction from the base of Personal Income Tax (PIT) of interest derived from
assimilable treasury bonds (Article 34)
Article 34 of the 2024 2024 Finance Act has exempted the interest income derived from assimilable
treasury bonds up to a limit of TND 10,000. Thus, the limit of TND 10,000 covers the following type of
interest received by the taxpayer from:
• - Special savings accounts opened with banks or the Caisse d’Épargne Nationale de Tunisie (National
Savings Bank of Tunisia);
• - Bond issues; or
• - Assimilable treasury bonds.

The following table summarizes interests deductibility’s limit:

Bond issues, assimilable treasury bonds, and Green, socially


Revenue special savings accounts opened with banks or responsible, or sustainable
the National Savings Bank of Tunisia (CENT) bond issues

TND 10,000, with deductible interest not


Plafond de déduction exceeding TND 6,000 for special savings
TND 10,000
Deduction threshold accounts opened with banks or the National
Savings Bank of Tunisia (CENT)

1.2 Non-counted interest on convertible bonds into shares and interest-free quasi-
equity issued by startups (Article 36)
Non counted interests on bonds convertible into shares and other equivalent categories of interest-free
equity, issued by startups, are not included in the taxable income of the purchaser of the bonds or the
equities.

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Personal income tax and corporate income tax

Finance Act 2024 Tax measures 2


2.
The 4 years exemption period starts as of the date
of effective start of business. The first year of
exemption is counted from the date of effective start
of business until December 31st of the same year.
For companies benefiting from regional development
area tax incentives, the 4 years of exemption are
counted from the date of the tax holiday period

TAX INCENTIVES
expiration as per domestic law for companies
established in regional development areas.
The benefit of the exemption is subordinated to the
2.1 4 years Exemption from PIT following requirements:
(Personal Income Tax) and CIT • Maintaining books in accordance with the
(Corporate Income Tax) for newly Tunisian GAAPs and;
established companies in 2024 and • Effective start of business within a period
2025 (Article 33) of 2 years as of the date of the investment
declaration.
Article 33 of the 2024 Finance Act provides
a 4-year exemption from PIT and CIT to newly
established companies that have received their
2.2 Extension by one year of the
investment declaration certificate from the relevant deadline granted to the parent company
authorities during 2024 and 2025. or holding company to proceed with the
The exemption applies to companies established company listing on BVMT (Tunis Stock
during 2024 and 2025 and having received a Exchange) (Article 35)
certificate of investment declaration from the
relevant sector-specific authorities during the same According to Article 11 of the PITCITC and point
period. The companies not covered by this tax 17 of Article 38 of the PITCITC, the capital gains
incentive are those operating in the financial sector, resulting from the contribution of shares to the
energy sectors (except renewable energies), mining, capital of the parent company or holding company
real estate development, on-site consumption, are exempt from taxation, provided that the parent
trade, and telecommunications operators. company or holding company proceeds with the
The exemption from PIT and CIT does not apply to: company listing on BVMT no later than the end
of the year following that of the deduction. This
• Companies created as part of transmission deadline can be extended by one year only by order
transactions or following the cessation of activity of the Minister of Finance based on a reasoned
or as a result of a change in the legal form of the report from the CMF (Financial Market Council).
existing company, to carryout the same activity
related to the same product or service. This tax benefit is granted if the following
conditions are met:
• Companies created by individuals who have been
engaged in an activity similar to the activity • The commitment of the parent company or
nature of the new company and having the holding company to proceed with its shares
status of shareholders or directors or those listing on the BVMT no later than the end of
having a first-degree family relationship (spouse the year following that of the deduction. This
or children) in another company engaged in an deadline can be extended by one year only by
activity similar to the activity nature of the new order of the Minister of Finance based on a
company. reasoned report from the CMF.

• • The filing by the taxpayer benefiting from the


deduction of the capital gain, of the above

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TAX INCENTIVES

commitment endorsed by the CMF, in support


of his annual tax return for the year of the
deduction.
• The filing by the taxpayer benefiting from the
deduction of the capital gain, of a certificate
proving the listing of the parent company or
holding company on the BVMT. This filing should
be performed at the relevant center or office
of Tax control, within a period not exceeding
the 3rd month of the 2nd year following that
of the deduction or exemption, or the 3rd year
following that of the deduction or exemption in
case of extension.
Article 35 of the 2024 Finance Act has eased the
condition related to the deadline for listing on the
BVMT. Indeed, to claim the tax exemption for the
capital gains resulting from the contribution, the
parent company or holding company must commit
to listing its shares on the BVMT no later than the
end of the 2nd year following that of the deduction
(instead of the end of the year following that of the
deduction). It remains possible for this deadline to be
extended by one year only by order of the Minister of
Finance based on a reasoned report from the CMF.
According to Article 35 of the 2024 Finance Act,
the above provisions apply to capital contribution
transactions to the capital of parent companies or
holding companies carried out starting from January
1st, 2024.

2.3 Fiscal over-amortization at the


rate of 30% applicable to assets in
alternative and renewable energies
(Article 48)
Article 48 of the 2024 Finance Act grants the
deductibility for CIT and PIT purpose of an additional
amortization of 30% of the gross value of the
equipment and machinery dedicated to alternative
or renewable energies production, acquired or
manufactured, during the first year from the date of
acquisition, manufacturing, or start of use, according
to the case.
The benefit of the deduction is subject to the
submission, in support of the annual tax return for
the year of the deduction, of a certificate issued by

Finance Act 2024 Tax measures 4


the competent bodies under the Ministry responsible It is worth noting that Tunisian administrative
for energy proving the category of the said doctrine (Common Note No. 2/2019), dealing with
equipment and materials. the fiscal over-amortization granted to the creation
and expansion operations governed by the LDI,
The new additional deduction is not cumulative
provided that the deduction of these amortization
with the additional deduction at a rate of 30%
cannot result in a deficit or worsening the deficit
granted by paragraph VIII of Article 12 bis of the
recorded before their deduction. Indeed, as specified
PITCITC (machinery and equipment acquired or
by the Common Note, this fiscal amortization is
manufactured as part of expansion or renewal
deductible from the taxable income after deducting
operations within the scope of Article 3 of the
all operating expenses, deficits, amortizations/
LDI (Investment Law), when it concerns the same
depreciations, and deferred amortizations/
equipment or materials.
depreciations. Furthermore, in case the covered
As in the case of the tax over-depreciation referred companies do not deduct fiscal over amortization
to paragraph VIII of Article 12 bis of the PITCITC, for PIT or CIT calculation purpose during the first
fixed assets that have benefited from the additional year from the date of acquisition, manufacturing,
deduction at a rate of 30% are not eligible for legal or start of use, the deferral of said deduction to a
revaluation. subsequent year is considered as an abandonment
The additional tax amortization of 30% provided by of their right to deduction. Consequently, the
the 2024 Finance Act: deduction of fiscal over-amortization cannot be
deferred to subsequent years.
• Applies to all companies, including those
operating in the financial sector, energy sectors
(except renewable energies), mining, real estate
development, on-site consumption, trade, and 2.4 Financial relief for investments in
telecommunications;
the green, blue, and circular economy &
• Is not subject to the realization of an investment
sustainable development (Article 49)
operation within the scope of the LDI; the 2024
Finance Act only requires the “submission,
Article 49 of the 2024 Finance Act has extended
in support of the annual tax return for the
the benefit of financial investment to companies
year of the deduction of a certificate issued
investing in the field of the green, blue, and circular
by the competent bodies under the Ministry
economy, as well as sustainable development, as
responsible for energy proving the category of
defined by current legislation and regulations.
the said equipment and materials”; it must be
the national agency for energy management The income or profits reinvested in the subscription
(ANME), which, under Article 17 of Law to the initial capital, or its increase of these
No. 2004-72 of August 2, 2004, on energy companies operating in the said fields are fully
management, is responsible for “granting deductible, within the limit of the income or profit
certificates for equipment, materials, and subject to tax.
products contributing to the rational use of
energy or related to renewable energies, in order
to benefit from the advantages provided by Furthermore, the deduction is subject to the
current legislation and regulations”; minimum tax provided for by Articles 12 and 12
bis of Act No. 89-114 of December 30, 1989,
• Does not require a minimum of an equity
promulgating the PITCITC, namely:
financing i.e., investment entirely fund by debt
gives right to the new benefit.

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TAX INCENTIVES

Taxpayers Minimum d’impôt

Individuals 45% of Personal Income Tax

Companies subject to a 15% corporate income tax rate 10% of the base of Corporate Income Tax

Companies subject to a 35% corporate income tax rate 20% of the base of Corporate Income Tax

In accordance with the provisions of Article 49 of the 2024 Finance Act, the aforementioned deduction
applies to income and profits invested from January 1, 2024, in the initial capital or its increase by
companies investing in the green, blue, and circular economy, as well as sustainable development.

2.5 Deduction of amounts invested in share issue premium for CIT or PIT
calculation purpose (Article 37)
According to Article 37 of the 2024 Finance Act, the share issue premium are part of invested amounts
which gives right to the deduction for CIT or PIT calculation purpose when subscribing to the increase in the
capital of companies, under the same limits and conditions.
This benefit is subordinated to the following conditions:
• The non-use of the share issue premium for a period of 5 years from January 1 of the year following its
release, except for its use for financing the related investment operation or absorbing losses.
• The presentation, in support of the annual tax return, of a copy of the decision of the extraordinary
general meeting approving the capital increase operation, including the value of the share issue
premium.
Consequently, the conditions related to the benefit of the deduction of financial investments for CIT or PIT
purpose are maintained.
According to Article 37 of the 2024 Finance Act, the aforementioned provisions apply to the deduction of
financial investments for income or profits made starting from January 1, 2024.

2.6Extension until December 31st, 2025, of the deadlines to benefit from the
transitional measures provided by the LRDAF for physical and financial relief
carried out under the auspices of the Tunisia Investment Incentive Code (CII) or the
PITCITC (Article 38)

Article 38 of the 2024 Finance Act has extended until December 31, 2025, the transitional measures
provided by paragraph 4 of Article 19 and paragraphs 3 and 4 of Article 20 of the LRDAF:

Investment in tangible & intangible assets (paragraph 4 of Article 19 of the LRDAF)


Income and profits invested by eligible companies within the companies themselves, benefiting from the
tax incentives provided by the PITCITC, remain subject to the legislation in force before April 1st, 2017,
provided that the investments become effective no later than December 31, 2025.

Finance Act 2024 Tax measures 6


Financial relief under the CII (paragraph 3
of Article 20 of the LRDAF)
Investment in the capital companies that obtained
a depositary certificate of investment declaration
deposit before April 1st, 2017, qualifying for tax
incentives under the CII, remain subject to the
provisions of that code, provided that the subscribed
capital is paid-up no later than December 31st,
2017, and the relevant investment becomes
effective no later than December 31, 2025.

Physical relief under the CII (paragraph 4


of Article 20 of the LRDAF)
Reinvestment operations of profits within the same
company, qualifying for tax incentives under the
CII and having received a depositary certificate of
investment declaration deposit before April 1st,
2017, remain subject to the provisions of that
code, provided that the effective start date of the
operation occurs no later than December 31, 2025.

2.7 Granting of tax incentives for the


acquisition of 8 and 9-seater transport
vehicles by organizations working in
the field of support and assistance
for individuals without family support
(Article 23)
In accordance with the provisions of Article 23 of
the 2024 Finance Act, organizations operating in
the field of support and assistance for individuals
without family support, and operating in accordance
with the legislation in force, benefit from the
exemption of VAT, customs duties, the unique tax
for road transport compensation, additional tax
on vehicles using LPG, circulation taxes, and the
annual tax on motor vehicles with heavy oil for the
acquisition of 8 or 9-seater vehicles listed under

tariff position 87-03.

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TAX INCENTIVES

2.8 Granting of the fiscal and customs


incentives for the importation or local
acquisition of a motorcycle or vehicle
for Tunisian residents abroad, once per
decade (Article 24)
In accordance with the provisions of Article 24 of
the 2024 Finance Act, Tunisian residents abroad can
benefit once every ten years from total or partial
exemption from duties and taxes on the importation
or acquisition in the local market of a motorcycle,
a passenger car, or a utility vehicle, including all-
terrain vehicles weighing not more than 3.5 metric
tons.
According to the provisions of Article 70 of the 2024
Finance Act, the provisions of the 2024 Finance Act
enter into force on January 1st, 2024.
Furthermore, Article 24 of the 2024 Finance Act
states pos that the conditions and implementation
modalities of this article will be determined by
decree.

2.9 Exemption of valued products used


for the production of renewable energies
from the tax on the destruction of
second-hand clothing (Article 52)
Article 52 of the 2024 Finance Act has exempted the
quantities valued within the framework of alternative
energy production from the aforementioned tax
imposed on the destruction of imported second-hand
clothing items.

Finance Act 2024 Tax measures 8


3.
VAT
3.1 Postponement to January 1, 2025, of the application of the 19% VAT rate on
sales of residential buildings exclusively used for housing by real estate developers
(Article 39)
Article 33 of the 2024 Finance Act has postponed the application of the 19% VAT rate due on the sales of
residential buildings exclusively used for housing, carried out by real estate developers to January 1st,
2025.

Property/Client Individuals Public real estate Other legal entities


developer

Residential buildings
exclusively used for
housing, including 13% from 2018 to 13% from 2018 to
their dependencies, 2024, then 19% 2024, then 19% 19%
including collective starting from 2025 starting from 2025
parking lots adjacent to
these buildings

Commercial,
administrative, or 19% 19% 19%
professional buildings

Lands 19% 19% 19%

It is important to recall that Article 44 of the Finance Act for 2018 states that sales contracts or promise
of sale contracts for operations concluded before January 1st, 2018, continue to benefit from the VAT
exemption under the regime prevailing before the entry into force of the Finance Act for 2018.

3.2 VAT rate reduction to 7% and 50% reduction in circulation taxes and first
registration taxes for electric vehicles (Article 50)
Article 50 of the 2024 Finance Act has reduced the VAT rate to 7% for motor vehicles equipped solely with
electric motors for propulsion falling under customs tariff numbers Ex 87.02, Ex 87.03, and Ex 87.04, as
well as bicycles falling under customs tariff number Ex 87.12, and motorcycles of various types equipped
solely with electric motors for propulsion falling under customs tariff number Ex 87.11.

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VAT

Designation of VAT before Finance VAT after Finance Act


N° of position
products Act 2024 2024

Motor vehicles for the


transport of more than
Ex 87.02 ten persons, equipped 19% 7%
solely with electric
motors for propulsion.

Other vehicles,
equipped solely with
Ex 87.03 19% 7%
electric motors for
propulsion.

Vehicles for the


transport of goods,
Ex 87.04 equipped solely with 19% 7%
electric motors for
propulsion.

Motorcycles (including
mopeds) and cycles
Ex 87.11 fitted with an auxiliary 19% 7%
motor, with or without
sidecars; sidecars.

Bicycles and other


cycles (including
Ex 87.12 19% 7%
tricycles), without a
motor.

Article 50 of the 2024 Finance Act has reduced circulation taxes by 50% for cars and motorcycles equipped
solely with electric motors. It has also reduced by 50% the first registration fee and the additional first
registration fee.

Finance Act 2024 Tax measures 10


3.3 Suspension of VAT for products intended for patients suffering from gluten
intolerance (Article 22)

Article 22 of the 2024 Finance Act provides for the suspension of VAT for the following products intended
for patients suffering from gluten intolerance:

N° of position Designation of products

Products and food preparations specifically intended


Ex 17.02
for patients who do not tolerate gluten

Products and food preparations specifically intended


Ex 19.01
for patients who do not tolerate gluten

Products and food preparations specifically intended


Ex 19.02
for patients who do not tolerate gluten

Products and food preparations specifically intended


EX 19.03
for patients who do not tolerate gluten

Products and food preparations specifically intended


Ex 19.05
for patients who do not tolerate gluten

Products and food preparations specifically intended


Ex 20.05
for patients who do not tolerate gluten

Products and food preparations specifically intended


Ex 20.07
for patients who do not tolerate gluten

Products and food preparations specifically intended


Ex 21.06
for patients who do not tolerate gluten

Products and food preparations specifically intended


Ex 21.07
for patients who do not tolerate gluten

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VAT

3.4 Revision of the scope and procedures for VAT exemption for boats, fishing
vessels, equipment intended to be incorporated, and fishing gear and nets (Article
26)
Article 26 of the 2024 Finance Act has excluded engines intended to be incorporated into boats and fishing
vessels from the scope of VAT exemption on importation and sale.
At the same time, the same Article has modified the conditions for benefiting from the exemption for local
acquisitions by removing visa from competent authorities of the ministry responsible for agriculture and
fisheries. However, the conditions for imports remain unchanged.

Conditions for VAT Exemption Before LF 24 After LF 24

- Invoice referred to by the competent authorities of the Ministry


responsible for agriculture and fisheries, and
- Commitment to not transfer ownership to anyone other than
Imports operators in the fishing sector, fishing shipowners, and industrial
users of the said materials and equipment intended to be
incorporated into fishing vessels and boats.

For the local acquisition of


Invoice referred to by the
materials, tools, and fishing
competent authorities of
Local acquisitions nets, sales invoices must
the Ministry responsible for
include the phrase “materials,
agriculture and fisheries.
tools, and fishing nets”

3.5 Exemption from customs duties and suspension of VAT for hay and silage
(Article 27)
Article 27 of the 2024 Finance Act provides for the suspension of VAT and the exemption from customs
duties on silage and hay, as follows:

Before Finance Act 2024 After Finance Act 2024


Customs tariff N° Products
VAT DD VAT DD

Ex 12149090 Silage 19% 10% Suspension 0%

Ex 12149090992 Silage 19% 0% Suspension 0%

Ex 12149090 Foin 19% 0% Suspension 0%

Finance Act 2024 Tax measures 12


4.
OTHER TAXES
4.1 New temporary contribution (Article 64)

Article 64 of the 2024 Finance Act has established a new temporary contribution for the benefit of the State
budget, applicable during 2024 and 2025. This optional tax is applicable to:
• Banks and financial institutions and;
• Insurance and reinsurance companies, including takaful insurance and reinsurance companies, as well as
the Members’ Fund.
This temporary contribution is set at 4% of the profits used as the basis for calculating the CIT, for which the
declaration deadline falls within the years 2024 and 2025, with a minimum annual amount of TND 10,000.
This temporary contribution is to be paid within the same deadlines and according to the same procedures
specified for the payment of CIT.
This contribution is not deductible for the CIT purpose.
The control of this contribution, the identification of infractions, and related legal disputes are conducted in
the same manner as for CIT.

4.2 Introduction of a tax on the importation and local production of dairy


derivatives (Article 47)

Article 47 of the 2024 Finance Act has established a tax on dairy derivatives, applicable to both imports and
local production. The tax is calculated based on kilograms as follows:

Customs tariff N° Products Amount of the tax in TND

EX04.06 Ricotta 1,500

EX04.01
EX04.02 Milk cream 2
EX04.03

Other cheeses, grated cheeses,


04,06 and others, excluding melted and 3
fresh cheeses (ricotta)

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OTHER TAXES

Finance Act 2024 Tax measures 14


The tax is due: •
• By manufacturers based on the quantities sold, Article 21 of the CDET states that the benefit of
similar to VAT regulations. the progressive registration fees provided by the
aforementioned Article 20 fourth is mandatory
• On imports based on the quantities imported,
and contingent upon the declaration, in the deed
excluding cheeses intended for processing and
of acquisition, that the land is acquired for this
imported by manufacturers.
purpose. The relevant authorities can only grant
The aforementioned tax is collected for local building permission if the buyer’s undertaking in
production based on a declaration, using a form the deed of acquisition is complied with. The buyer
established by the administration, submitted by the forfeits the benefit of the progressive registration
taxpayers within the same deadlines as specified for fees and is required to pay duties, as well as
VAT and customs duties on imports. penalties, in either of the following cases:
The same rules applicable to VAT or customs duties, • Sale of the land before the construction is
as appropriate, apply to the tax regarding control, performed;
identification of infractions, penalties, disputes,
• Change in the intended use of the acquired land,
prescription, and refunds.
as specified in the deed of acquisition.
In accordance with the provisions of Article 70 of
According to Article 53 of the 2024 Finance Act,
the 2024 Finance Act, the regulations outlined in
registration under the progressive rates outlined in
the 2024 Finance Act enters into force on January
No. 4 of Article 20 of the CDET is granted only once
1, 2024. The same article also states that the
for the first acquisition operation.
provisions of Articles 44, 47, 55, and 66 of the
2024 Finance Act, relating to the increase of duties
and taxes, do not apply to imported goods: 4.4 Increase of compensation royalties
• For which the transport documents, issued and broadening of their scope (Article
before the entry into force of this Act, justify 45)
their shipment to the Tunisian customs territory,
Article 45 of the 2024 Finance Act has amended
• And which are declared for direct consumption the provisions of Paragraph I of Article 63 of
without being placed under the regime of Law No. 2012-27 dated December 29th, 2012,
warehouses or free zones. which constituted the Finance Act for 2013. This
amendment expands the scope of the compensation
4.3  Restriction of the progressive royalty, increases its rate to 3% or 5% of the local
turnover excluding duties and taxes, and reviews its
registration benefit to the first recovery methods:
acquisition of residential land (Article
The rate of the compensation royalty is set at 3% for:
53)
• Tourist establishments providing accommodation
Article 20 fourth of the CDET (Registration and services,
Stamp Fees Code) allows the registration of
acquisitions of land intended for the construction • Tourist-classified restaurants,
of individual residential buildings under progressive • Franchised restaurants of a foreign brand or
rates as follows: commercial sign,
• Up to 120 m²: 1% • Bars,
• From 120,001 to 300 m²: 2% • Tea rooms,
• From 300,001 to 600 m²: 3% • Cafés of the 2nd and 3rd categories,
• Beyond 600 m²: 5% • Industries producing carbonated beverages,
beers, wines, and alcoholic beverages. The

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OTHER TAXES

turnover generated between industrial entities is excluded from the application of this royalty.
• The rate of the royalty is increased to 5% for:
• Casinos and nightclubs not affiliated with a tourist establishment and;
• Cabarets and pastry shops. Pastry shops exclusively producing traditional popular pastries, as
determined by the decree of the Minister of Finance, are exempted from this royalty.
Article 45 of the 2024 Finance Act specifies that the royalty is based on the local turnover excluding duties
and taxes.
The royalty is collected as follows:
• For individuals subject to PIT under the real regime or CIT, based on a monthly or quarterly return, within
the same deadlines and using the same procedures as applied in VAT matters,
• For individuals subject to PIT under the lump-sum regime, within the same deadlines and using the same
procedures as applied in PIT matters.
Finally, note that the 2024 Finance Act has not modified Paragraph II of Article 63 of Act No. 2012-27
dated December 29th, 2012, which states that the compensation royalty is not taken into account for the
determination of taxable profit for individuals liable for this royalty.

4.5 Increase in tax on international flights and tax on entry of travelers by


maritime transport (Article 51)
Article 51 of the 2024 Finance Act has increased the tax on international flights and the tax on entry of
travelers by maritime transport as follows:

After Finance Act 2024


Before Finance
Taxe
Act 2024
Tax amount First class or business class

Tax on international
flights and tax on entry
TND 20 TND 40 TND 60
of travelers by maritime
transport

No changes have been made to the exemptions provided by these taxes. Exemptions from the tax on
international flights and the tax on entry of travelers by maritime transport in Tunisia include:
• Transit passengers,
• Children under 2 years,
• Travelers on aircraft chartered by a foreign state for an official visit,
• Tourist cruise passengers.

4.6 Increase in the tax on energy products (Article 51)


Article 51 of the 2024 Finance Act outlines an increase in the tax on consumed energy products as stated in
the fourth hyphen of Article 13 of Act No. 2005-106 dated December 19th, 2005, Finance Act for 2006,
as follows:

Finance Act 2024 Tax measures 16


Designation of products Before Finance Act 2024 After Finance Act 2024

Super unleaded gasoline 1 millime per liter 5 millimes per liter

Regular diesel 1 millime per liter 5 millimes per liter

Diesel 50 2 millimes per liter 10 millimes per liter

Fuel oil 1 DT per metric ton 5 DT per metric ton

Liquefied petroleum gas 1 DT per metric ton 5 DT per metric ton

Petroleum coke 2 DT per metric ton 10 DT per metric ton

Natural gas 0.25 millime per thermal unit 1.25 millimes per thermal unit

Natural gas 1 millime per kilowatt-hour (kWh) 5 millimes per kilowatt-hour (kWh)

4.7 Increase in the tourist tax for foreigners other than UMA nationals (Article 46)
According to Article 46 of the 2024 Finance Act, the scope of application of the tourist tax has been
expanded, and its amount has been reviewed as follows:

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OTHER TAXES

Taxpayer liable for the Before Finance Act 2024 After Finance Act 2024 (per night)
tax (per night)
Tunisians and UMA Foreigners
2 stars tourist hotels 1 DT 1 DT 4 DT
3 stars tourist hotels 2 DT 2 DT 8 DT
4 stars tourist hotels 3 DT 3 DT 12 DT
5 stars tourist hotels 3 DT 3 DT 12 DT
Apart-hotels
Holiday villages
Guesthouses
Charming hotels or
tourist residences
Motels
Camps
0 TND 1 TND 4
Rural lodgings
Bed and breakfasts
All other premises
intended for rent in
the form of rooms,
apartments, or villas for
limited duration stays

The tax paid by each resident cannot exceed a threshold calculated based on 10 successive overnight stays.

4.8 Increase of the taxation of export bulk olive oil (Article 16)
Article 16 of the 2024 Finance Act provides that the “Fund for the Promotion of packaged Olive Oil” is
funded by:
• 50% of the returns from a tax applied at a rate of 2% of the customs value on the export of bulk olive oil,
falling under customs tariff numbers 150920009, 150930009, 150940009, and 150990008,
• 50% of the returns from a tax due at a rate of 4% of the customs value on the export of crude lampante
olive oil in bulk, falling under customs tariff number EX150940, and crude olive pomace oil in bulk,
falling under customs tariff number 15101000000.
For the application of these provisions, Article 16 of the 2024 Finance Act specifies the following:
• Bulk olive oil of all types is oil exported in containers with a capacity exceeding 5 liters.
• Sales operations of bulk olive oils of all types to exporting companies operating according to the
specifications for the olive oil packaging activity are not subject to these taxes.
Finally, Article 16 of the 2024 Finance Act provides for the allocation of 50% of the proceeds from taxes on
the export of bulk olive oil, crude lampante olive oil in bulk, and bulk olive pomace oil to the benefit of the
Export Promotion Fund (FOPRODEX).

Finance Act 2024 Tax measures 18


4.9 Increase in registration fees for vehicles and transport permits (Article 68)
In accordance with Article 68 of the 2024 Finance Act, the taxes for administrative procedures related to
vehicle registration, driving licenses, learning, teaching, and training in the field of vehicle driving, as well as
operation cards and transport authorization, are set as follows:

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OTHER TAXES

Prestation Before FL 2024 After FL 2024

I. Vehicle registration certificate:


1) Registration, re-registration, or transfer of vehicles:
A—Motor vehicles:
- Up to 5 HP 60 120
- Above 5 HP and for each additional unit 5 10
B— Motorcycles, mopeds, tricycles, and quadricycles with engines
- Up to 2 HP 4,520 10,520
- Above 2 HP and for each additional unit 2 4
C — Tractors, agricultural machinery, public works or industrial equipment, and special vehicles 10,520 20,520
D — Trailers and semi-trailers 10,520 20,520
2) Duplicate of a vehicle registration certificate:
- Duplicate of the registration certificate for any type of vehicle 10,520 20,520
3) Miscellaneous operations:
A— Isolated reception of a vehicle following a substantial change 30 60
B— Vehicle status certificate 5 10
C — Transcription or removal of a lien 5 10
D — Issuance of a special circulation card for vehicles intended for testing or sale 100 200
E— Stamping of the chassis number or manufacturer’s plate of a vehicle, 10 20
F— Certificate of the empty weight of a vehicle or the number of seats 5 10
II. Learning, teaching, and training driving licenses
1) Driving license:
A— Theoretical test 5
B— Practical test 5 10
C — Issuance of a driving license 5 10
D — Renewal of a driving license 5 10,520
E— Duplicate of a driving license 10,520 10,520
F— Exchange of a foreign driving license for a Tunisian license 5,520 20,520
G— Exchange of a military license for a driving license 5,520 10,520
H— Authenticity certificate for a driving license 5 10,520
2) Learning, teaching, and training in the field of vehicle driving:
A— Examination for obtaining a certificate of professional aptitude for teaching traffic rules and 5 10
road safety, or a certificate of professional aptitude for teaching vehicle driving, or a certificate of
professional aptitude for training driving instructors
B— Issuance of a certificate of professional aptitude for training in traffic rules and road safety, or
5 10
a certificate of professional aptitude for training in vehicle driving, or a certificate of professional
aptitude for training driving instructors
C- Issuance of a license for a traffic rules and road safety instructor, or a vehicle driving instructor, or a
5 10
vehicle instructor trainer, or a temporary professional license
D — Renewal of a license 5
10
E— Issuance of a duplicate license 5 10
F— Equivalence certificate for a foreign certificate related to vehicle driving training to a Tunisian
certificate 5 10
G— Authenticity certificate for a professional aptitude certificate or an equivalence certificate 5 10
III. Operation Card for one of the land transport activities:
-First establishment 10 20
-Replacement of a vehicle 10 20
-Expansion of a parc 5 20
-Renewal of an operation card 5 10
-Duplicate of an operation card 10

The aforementioned taxes are paid by the land transport technical agency based on a monthly return
according to a model established by the administration to be submitted to the finance department within
the same deadlines as the submission of monthly returns for legal entities that submit their returns and pay
their taxes and related penalties through reliable electronic means remotely.

Finance Act 2024 Tax measures 20


4.10 Reduction of the export tax on mining and quarrying products (Article 41)
Article 41 of the 2024 Finance Act provides for the reduction of the export tax on mining and quarrying
products as follows:
Amount per ton before Amount per ton after
Customs tariff N° Wording
FL 2024 FL 2024

Natural sands of all


25,05 TND 100 TND 50
kinds

Marbles and other


25,15 TND 250 TND 200
natural stones

21 | Finance Act 2024 Tax measures


TAX OBLIGATIONS & PROCEDURES

5.
TAX OBLIGATIONS & PROCEDURES
5.1 Revision of the deadline for submitting the monthly income Tax return for
individuals registered under electronic tax filing system (Article 69)
Article 69 of the 2024 Finance Act has reduced the deadline for submitting the monthly tax return for legal
entities using reliable electronic means remotely for the return and payment of taxes and related penalties
as follows:

Taxpayers Electronic declaration Deadline before FL 24 Deadline after FL 24


Without electronic tax filing
Individuals Until the 15th day of the following month for which the return is filed
With electronic tax filing

Until the 28th day of the month following the one for which the return is
Without electronic tax filing
submitted
Legal entities Until the 28th day of the month Until the 20th day of the month
With electronic tax filing following the one for which the following the one for which the
return is submitted return is submitted

5.2 Revision of late filing penalties and fixed penalties (Article 61)

Revision of fixed penalties of tax basis in the case of spontaneous payment without prior
intervention from tax control authorities
The first paragraph of Article 61 of the 2024 Finance Act has amended the rates of the fixed penalty of tax
basis due in the case of spontaneous payment as follows:

Delay in the case of spontaneous Fixed tax basis penalties before Fixed tax basis penalties after FL
payment FL 24 24
Between 0 and 60 days 3% 0%
>60 days 5% 3%

When the tax due is spontaneously paid without prior intervention of the tax control authorities, the
amendment introduced by the 2024 Finance Act implies that in case of a delay of less than 60 days, only
late penalties are imposed at the rate of 1.25% of the amount of the tax per month or fraction of a month of
delay.
According to the 7th paragraph of Article 61 of the 2024 Finance Act, these provisions apply to tax returns
submitted spontaneously starting from January 1, 2024.

Finance Act 2024 Tax measures 22


than 30%.

Capping of late penalties and fixed Consequently, in case of tax audit, the late payment
penalties in case of spontaneous payment penalty of 2.25% per month or fraction of a month is
increased by a fixed penalty paid at the rate of 10%,
without prior intervention from the tax which will be raised to 20%, only for the following
control authorities cases:
In accordance with the 2nd paragraph of Article 61 • VAT, other taxes on sales, and WHT not remitted
of the 2024 Finance Act, the total of penalties (late to the Treasury and;
penalties calculated at the rate of 1.25% per month
or fraction of a month of delay and fixed penalty of • Reduction in turnover equal to or greater than
3%) is capped at the amount of the principal. 30% or;

According to the 7th paragraph of Article 61 of • Committed acts of tax fraud.


the 2024 Finance Act, these provisions apply to In cases of application of the 20% increase in
tax returns submitted spontaneously starting from the fixed base penalty following the reduction in
January 1, 2024. turnover and tax fraud acts align with the cases of
Elimination of the increase on the fixed penalty from penalization provided by Article 101 of the FRPC,
10% to 20% in case of a tax liability decision in case with a few differences:
of failure to file the tax returns and acts prescribed • Article 101 of the FRPC applies when the
by law for the establishment of the tax, as well as reduction in turnover is strictly greater than 30%,
failure to present the accounting records whereas the application of the 20% increase in
The 3rd paragraph of Article 61 of the 2024 Finance the fixed base penalty margin is imposed when
Act has abolished the increase in the fixed penalty the reduction is equal to or greater than 30%.
from 10% to 20% in the following cases: • The application of Article 101 of the FRPC
• In case of tax liability decision in accordance with assumes that the taxpayer has evaded payment
the provisions of the 2nd paragraph of Article 47 of VAT or DC only, whereas the application of the
of the FRPC, or 20% increase in the fixed base penalty covers all
undeclared indirect taxes.
• In case of failure to submit the accounting
records within the deadlines set out in Articles Finally, according to the 8th paragraph of Article 61
38 and 41 bis of the FRPC. of the 2024 Finance Act, these provisions apply:

According to the 8th paragraph of Article 61 of the • To tax audit which results have been notified
2024 Finance Act, these provisions apply: starting from January 1, 2024,

• To tax audit operations that have been subject • To tax liability decision established within the
of a notification of the results of the tax audit scope of the 2nd paragraph of Article 47 of
starting from January 1, 2024, the FRPC and notified starting from January 1,
2024.
• To tax liability decision established within the
meaning of the 2nd paragraph of Article 47 of Reduction of penalties in case of
the FRPC and notified starting from January 1, intervention of the tax control authorities
2024. following the payment of additional taxes
Easing the conditions for the application of in cash
the 20% fixed penalty in case of tax audit According to the 4th paragraph of Article 61 of the
In accordance with the 3rd paragraph of Article 61 of 2024 Finance Act, the rate of the late penalty of
the 2024 Finance Act, the fixed penalty is paid at the 2.25% per month or fraction of a month is reduced
rate of 20% of the amount of the due tax triggered to 1.25% (previously 1.5%) following the payment
by a reduction of sales amount equal to or greater of additional taxes in cash. No modification is made
for the reduction of the fixed penalty rate, which

23 | Finance Act 2024 Tax measures


TAX OBLIGATIONS & PROCEDURES

remains reduced by 50% (i.e., reduced from 10% to 5% and from 20% to 10%). Also, no changes are made to
the conditions for benefiting from this reduction, which remains subject to the dual condition:
• That the due tax is paid within a maximum period of 30 days from the date of the recognition of the debt
and;
• That the recognition of debt occurs before the notification of the tax liability decision .

Penalty Before FL 24 After FL 24


Late penalties 1,5% (instead of 2,25%) 1,25% (instead of 2,25%)
Fixed assessment penalties 5% (instead of 10%)/10% (instead of 20%)

According to the 9th paragraph of Article 61 of the 2024 Finance Act, these provisions apply to payment
transactions carried out starting from January 1, 2024.
Capping of late penalties and fixed base penalties in case of intervention by tax control authorities
In accordance with the 5th paragraph of Article 61 of the 2024 Finance Act, the total of penalties (late
penalties assessed at the rate of 2.25% or 1.25% per month or fraction of a month of delay and fixed
assessment penalty of 10% or 20%) has been capped at the amount of the principal.
According to the 10th paragraph of Article 61 of the 2024 Finance Act, these provisions apply to:
• Tax audit operations that have been the subject of a notification of the results of the tax audit or a
notification of a tax liability decision starting from January 1, 2024,
• Tax liability decision established within the scope of the 2nd paragraph of Article 47 of the FRPC and
notified starting from January 1, 2024,
• Payment transactions carried out starting from January 1, 2024.

5.3 Revision of the rules for referring to the reconsideration Commission for tax
liability decision (Article 57)
Article 57 of the 2024 Finance Act introduced the following amendments to the rules for referring to the
reconsideration commission for tax liability decision:
• The jurisdiction of the reconsideration Commission for tax liability decision has been limited to cases in
which a final judgment has declared the taxpayer’s appeal inadmissible for procedural reasons.
• A deadline has been introduced for the taxpayer to request the referral to this Commission. The taxpayer
must make this referral request within a period not exceeding one year from the date on which the
judgment became final.
In addition, the right to reconsideration before the said Commission no longer applies to:
• The taxpayer who has received the tax liability decision and has not filed a judicial appeal against this
order or;
• The taxpayer who has received the tax liability decision, has filed a judicial appeal against this decision
outside the legal deadline, and against whom a judgment of inadmissibility of said appeal is pronounced
for exceeding this legal deadline or;
• Taxpayers who have not presented their accounting records during the administrative phase of the audit,
despite receiving the prior notice of the in-depth or spot tax audit.
Furthermore, no changes have been made by the 2024 Finance Act to the other conditions for referring to

Finance Act 2024 Tax measures 24


the reconsideration Commission for tax liability decisions previously provided for by Article 127 of the FRPC:
• The reconsideration Commission for tax liability decisions only reviews decisions for which no judgment
on the merits has been pronounced.
• In case of no opposition against the tax liability decision within the 60-day period, the reconsideration
request must be submitted before the expiration of the 5th year following the one in which the tax
decision is notified.
• The tax administration can still, on its own initiative, refer the Commission for reconsideration of tax
liability decisions.

5.4 Revision of the rules for taxation of certain administrative tax fines (Article 62)
Establishment of a prior formal notice procedure before tax liability for administrative tax
fines covered by Articles 84 bis, 84 nonies, and 85 of the FRPC
Article 62 of the 2024 Finance Act introduced a mandatory prior formal notice for the following
administrative tax fines:
• Administrative tax fine for non-compliance with the procedure provided for in Article 112 of the FRPC
(20% of the income or profits transferred, should the transfer of income or profits taxable in Tunisia de
concerned , or 1% should the transfer of non-taxable income or profits be concerned).
• Fines related to the annual return of transfer pricing (TND 10,000 for failure to submit and TND 50 per
incomplete or inaccurate information to upper fine limit of TND 5,000).
• Fine for failure to declare exempted income and profits or subject to a flat-rate WHT (1% of income and
profits exempt from PIT and CIT or subject to a flat-rate WHT).

Appeal of administrative tax fines provided for by Articles 84 quater and 84 quinquies of
the FRPC in the context of tax audit procedures
With Article 62 of the 2024 Finance Act, the following administrative tax fines are claimed within the tax
audit procedures:
• Fine for non-declaration of cash recoveries (8% of the value of the amounts recovered) and;
• Fine in case of VAT deduction during the non-accounting reconstruction of turnover (50% of the VAT
amount).
As a result, these 2 fines will no longer be the subject of separate tax liability decision independent of the
notification of the results of the audit. Therefore, they should be included in these results. Beyond the oral
and contradictory debate with the taxpayer, the challenge to these 2 fines will follow the same procedures
provided for by the FRPC for tax audits (opposition from the taxpayer, response from the administration,
taxpayer’s reply to the administration’s response, referral to the conciliation Commission). After the
intervention of the 2024 Finance Act, these 2 fines will be subject to the same procedures as the following
administrative penalties:
• Penalty for default or insufficiency of WHT provided for in Article 83 of the FRPC;
• Fine provided for in Article 83 bis of the FRPC for default or insufficiency of the advance provided for in
Article 51 quater or the advance provided for in Article 51 septies of the PITCITC;
• Fine provided for in Article 83 ter of the FRPC for cash payments of amounts greater than or equal to
TND 5,000;
• Penalty provided for in Article 84 of the FRPC for default or insufficiency in the payment of stamp duties

25 | Finance Act 2024 Tax measures


TAX OBLIGATIONS & PROCEDURES

and;
• Penalties for undue restitutions provided for in Article 32 of the FRPC.

In accordance with the provisions of the 3rd paragraph of Article 62 of the 2024 Finance Act, the above
provisions apply to:
• Administrative tax fines applied starting from January 1, 2024, for offenses under Articles 84 bis, 84
nonies, and 85 of the FRPC, including offenses committed before that date,
• Tax audit operations that have been subject, from January 1, 2024, of a notification of a request for
information, clarification, or justification or a prior audit notice, for the offense provided for in Article 84
quater of the FRPC,
• Tax audit operations that have been subject, starting from January 1, 2024, of a notification of a prior
audit notice, for the offense provided for in Article 84 quinquies of the FRPC.

5.5 Strengthening of sanctions related to the communication fee (Article 54)


Article 54 of the 2024 Finance Act has strengthened the sanctions of Article 100 bis of the FRPC, which are
related to the communication fee provided for in Articles 17 and 17 bis of the same code:

Designation of products Before Finances Act 2024 After Finances Act 2024
Fine for failure to comply with the
provisions of Articles 17 and 17 bis From TND 1 000 to TND 20 000 From TND 5 000 to TND 50 000
of the FRPC

Margin for non-disclosure of TND 100 per piece of information TND 200 per piece of information
information or for inaccurate or not disclosed or disclosed not disclosed or disclosed
incomplete communication inaccurately or incompletely inaccurately or incompletely

5.6 Qualification of the head of tax control office to establish tax liability decision
in case of failure to submit tax returns and acts prescribed by law for tax
assessment (Article 63)
According to Article 63 of the 2024 Finance Act, tax liability decision can be established in the case provided
for in the 2nd paragraph of Article 47 of the FRPC — in case of the taxpayer’s failure to submit tax returns
and acts prescribed by law for tax assessment — by the head of the relevant tax control office. This new
qualification does not prejudice the old qualification rules provided for in Article 50 of the FRPC. In case of
failure, the Director-General of Taxes, the head of the national tax control and investigation unit, the director
of medium-sized enterprises, the director of large enterprises, or the head of the regional tax control center
remain empowered to establish tax liability decision, even with the legislative intervention of the 2024
Finance Act.
It is recalled that tax liability is established in case of the taxpayer’s failure to submit tax returns and acts
prescribed by law for tax assessment, within a maximum period of 30 days from the date of notice to the
taxpayer in accordance with the procedures provided for in Article 10 of the FRPC. According to Article 48
of the FRPC, tax liability is established based on legal or factual presumptions or on the amounts reported on
the last return.

Finance Act 2024 Tax measures 26


5.7 Clarification of the conditions for
applying the fine for non-disclosure
of information on the TCL distribution
(Article 67)
Pursuant to Article 67 of 2024 Finance Act, the
same provisions of the TNB apply to the fine of 1
000 DT for each undeclared quarry or building that
is not covered or built on.
It is specified that, according to Article 10 of the
CFL, the collection of the TIB is carried out by
the relevant finance receivers, through an annual
roll established by the local authority and can be
updated during the year for each control operation.
The roll becomes enforceable as soon as it is
signed by the president of the local authority and
constitutes a collection title for the TIB for the
entire period covered by the census, taking into
account updates and additions made by the local
authority. The collection of the tax is made for each
debtor based on an extract from the individual roll
endorsed by the finance receiver, the accountant
of the local authority. According to Article 23 of
the CFL, taxpayers can file their objections with
the review commission within one month from the
day they become aware of the amount of tax due
on their properties. According to Article 26 of the
CFL, any taxpayer can file an appeal for the review
of the tax with the territorially competent cantonal
Court within sixty days. The appeal for review to
the cantonal Court does not suspend the collection
of the contested tax, which is the subject of the
dispute. The judgment rendered by the court is final.

27 | Finance Act 2024 Tax measures


AMNESTY

6.
AMNESTY
6.1 Establishing a tax amnesty for TIB, contribution to the National Fund for
Housing Improvement, and TNB (Article 59)
Article 59 of the 2024 Finance Act has introduced an amnesty regarding TIB, the contribution to the
National Fund for Housing Improvement, and TNB.
For individuals
The amounts due for TIB, contribution to the National Fund for Housing Improvement, and TNB for the year
2021 and previous years, along with the associated late penalties and prosecution costs, are entirely waived
for individual taxpayers.
The benefit of these provisions is subject to:
• Payment of the total taxes due for the year 2024,
• Payment of the total amounts due for the years 2022 and 2023 or the underwriting to a payment
schedule in quarterly installments for a period not exceeding 2 years. The first installment must be paid
no later than December 31, 2024.
The payment schedule during the aforementioned maximum period will be determined, based on the
amounts, by order of the Minister of Finance.
Costs of prosecution and late penalties for the years 2022 and 2023 are waived for adherents to
regularization.
For legal entities
Late penalties and prosecution costs related to TIB, contribution to the National Fund for Housing
Improvement, and TNB for the year 2023 and previous years are waived for legal entities liable for these
taxes.
The benefit of these provisions is subject to:
• Payment of the total taxes due for the year 2024,
• Subscription to a payment schedule for the amounts due for the year 2023 and previous years in
quarterly installments for a period not exceeding 3 years. The first installment must be paid no later than
December 31, 2024.
The payment schedule during the aforementioned maximum period will be determined, based on the
amounts, by order of the Minister of Finance.

Finance Act 2024 Tax measures 28


Amnesty Individual Legal entity
Object TIB, contribution FNAH and TNB TIB, contribution FNAH and TNB
Principal for 2021 and previous
Late payment penalties and
years + Late payment penalties
Years amnestied prosecution costs for 2023 and
and prosecution costs for 2021
previous years
and previous years
Immediate payment Total taxes due for the year 2024 Total taxes due for the year 2024
Immediate payment 2022 and 2023 2023 and previous years
Deadline for payment of the 1st
December 31, 2024 December 31, 2024
installment
Maximum rescheduling period
2 years 3 years
(order)

6.2 Establishing a tax amnesty for taxes due to the Treasury (Article 58)
Article 58 of the 2024 Finance Act introduces a tax amnesty covering:
• Tax liabilities recorded in the tax authorities’ books including those due to local tax authorities, hospitality
tax, and license fees.
• Fines, financial penalties and administrative tax infringements.
• Missing tax returns and contracts registration.
• Road Tax.

Regarding tax liabilities recorded in the tax authorities’ books including those due to
local tax authorities, hospitality tax, and license fees:
In accordance with the first paragraph of Article 58 of the 2024 Finance Act, late payment penalties and
enforcement costs related to state tax claims are waived, provided a payment schedule is submitted before
June 30, 2024. The amounts must be paid in quarterly maturities over a period not exceeding 5 years,
with the first maturity paid in cash before the specified date.
The payment schedule is set within the aforementioned maximum duration by order of the Minister of
Finance, based on the importance of the amounts.
The provisions for waiving penalties and prosecution costs apply to:
• Liabilities recorded in the tax authorities’ books before January 1, 2024,
• Liabilities not recorded in the tax authorities’ books before January 1, 2024, which have been covered
by a reconciliation agreement with tax authority before June 20, 2024, or have been acknowledged as a
debt or notified by a tax liability decision before the same date,
• Tax liabilities due by judgments handed down before June 1st, 2024, related to tax liability decision.
These provisions of this paragraph apply to liabilities recorded under TCL, hotel tax, and license fees.
Referring to paragraph 5 of Article 58 of the 2024 Finance Act, the application of abandonment procedures
cannot result in the refund of amounts to the debtor or the revision of the accounting entry of amounts paid,
except in cases that have been subject to a final judgment.

29 | Finance Act 2024 Tax measures


AMNESTY

Regarding fines, financial penalties, and Regarding Road tax


administrative tax infringements According to paragraph 4 of Article 58 of the 2024
According to paragraph 2 of Article 58 of the 2024 Finance Act, road tax due for the years 2020,
Finance Act, the following are waived: 2021, and 2022, including taxes subject to penal
tax minutes drafted before January 1, 2024, are
• Fines and financial penalties recorded in the
waived, provided that circulation taxes due for the
tax authorities’ books before January 1, 2024,
years 2023 and 2024 are paid within the deadlines
whose remaining amount does not exceed
prescribed by current legislation and within a period
TND 100 for each fine, along with the related
not exceeding December 31, 2024.
prosecution costs.
Possibility of extension of payment schedules
• 50% of the amount of fines, financial penalties
and administrative tax infringements recorded According to paragraph 5-b of Article 58 of the
before June 20th, 2024, along with the related 2024 Finance Act, the extension of payment
enforcement costs, provided that a payment schedules may be granted without exceeding the
schedule is arranged before June 30th, 2024, maximum period set for this purpose (5 years),
and the amounts due are paid in quarterly based on a reasoned request from the debtor
maturities over a period not exceeding 5 addressed to the competent finance receiver.
years, with the first maturity paid before the
Amnesty impacts:
aforementioned date.
Procedures for pursuing each debtor who commits
The above-mentioned abandonment procedures do
to paying the maturities at their due dates are
not apply to fines and financial penalties related to
suspended. The non-payment of a due maturity
insufficient fund cheques and infringements related
leads to the resumption of prosecution procedure
to anti-terrorism and anti-money laundering.
for its recovery. For each unpaid maturity related to
Referring to paragraph 5 of Article 58 of the 2024 tax liabilities owed to the State and liabilities owed
Finance Act, the application of abandonment to local authorities within the specified deadlines, a
procedures cannot result in the refund of amounts late payment penalty at the rate of 1.25% per month
to the debtor or the revision of the accounting entry or fraction of a month applies, calculated from the
of amounts paid, except in cases that have been expiration of the payment deadline.
subject to a final judgment.
Amounts not paid within 120 days from the
Regarding missing tax returns and expiration of the payment deadline of the last
contracts registration maturity set by the payment schedule are no longer
eligible for the benefits of provisions regarding the
According to paragraph 3 of Article 58 of the 2024 waiver of penalties, enforcement costs, fines, and
Finance Act, penalties provided for in articles 81, financial penalties; the unpaid amounts remain due
82, and 85 of the FRPC are waived for tax returns, in principal and penalties without any deduction.
including contracts, deeds, and declarations related
to registration fees, that are not prescribed, due The application of the provisions of Article 58 of
before October 31, 2023, and filed from January 1, the 2024 Finance Act, in any case, does not prevent
2024, to April 30, 2024, provided that the principal the taxpayer from exercising their rights in court
tax is paid, as applicable, at the time of declaration and seeking the restitution of amounts collected in
or registration procedure. excess.

These provisions apply to default tax returns, as Cases of decisions on restitution:


well as amended returns, even if filed during the tax According to the last paragraph 5 of Article 58 of
audit period and the period after the Notification of the 2024 Finance Act, notwithstanding the schedule
the Reassessments. established to benefit from the amnesty, the
provisions of Article 33 of the FRPC are applicable
to the amounts of taxes that have been subject to

Finance Act 2024 Tax measures 30


decisions on restitution.
For reference, Article 33 of the FRPC provides
that the restitution of amounts collected in
excess is made after deducting tax claims
recorded in the accounts of the finance receiver
against the person who requested restitution
or their successor, even if these claims are still
partially or entirely in dispute.

6.3 Regularization of import files for


vehicles exclusively for the transport
of persons with disabilities (Article
60):
Article 60 of the 2024 Finance Act has
regularized the status of files related to the
importation of vehicles specifically intended for
use by persons with disabilities, submitted to
customs services before January 1, 2023, based
on the rates and conditions in effect at the date
of their importation, with the exemption of
applicable penalties.
The application of these provisions may not lead
to the refund of amounts paid before January 1,
2024.

31 | Finance Act 2024 Tax measures


CUSTOMS

7.
CUSTOMS
7.1 Customs penalty threshold for secured obligations (Article 61):
Paragraph 6 of Article 61 of the 2024 Finance Act states that the amounts payable for late interest as
provided in paragraph 3 of Article 130 of the Customs Code must not exceed the principal amount of the
debt in any case.
According to the 11th paragraph of Article 61 of the 2024 Finance Act, the provisions of paragraph 6 of the
same article apply to customs liabilities recovered starting from January 1, 2024, regardless of the date of
the claim, without resulting in the refund of amounts to the debtor or the revision of the accounting entry of
amounts paid, except in cases subject to a judgment with the force of res judicata.

7.2 Introduction of exceptional tariff measures on a list of products imported from


Turkey (Article 44):
According to Article 44 of the 2024 Finance Act, notwithstanding the tariff positions covered by Article 40
of Act No. 2017-66 of December 18, 2017, regarding the Finance Act for 2018, as amended by Article
52 of Act No. 2019-78 of December 23, 2019, regarding the Finance Act for the year 2020, products
originating from Turkey falling under the tariff positions listed in Appendix No. 1 are subject to customs
duties up to 75% of the duties applied under normal circumstances. This is subject to the rates of customs
duties consolidated by the agreement on the establishment of a free trade zone between the Republic of
Tunisia and the Republic of Turkey signed in Tunis on November 25, 2004, and approved by Law No. 2005-
36 of May 11, 2005.
In accordance with the provisions of Article 70 of the 2024 Finance Act, the provisions of the 2024 Finance
Act apply starting from January 1, 2024.
The same article states that the provisions of Articles 44, 47, 55, and 66 of the 2024 Finance Act related to
the increase in duties and taxes do not apply to imported goods:
• Whose transport documents, issued before the entry into force of this law, justify their shipment to the
Tunisian customs territory, and
• Which are declared for direct consumption without having been placed under the regime of warehouses
or free zones.
Finally, under Article 44 of the 2024 Finance Act, customs duties are exceptionally applied to Turkish origin
products for a duration of 3 years, starting from January 1, 2024. These duties will be abolished after the
expiration of the 3-year period, gradually from the 4th year of the implementation of this measure, over 2
years at equal rates.

Finance Act 2024 Tax measures 32


7.3 Increase of the minimum amount for customs declarations from TND 10 to
TND 20 (Article 66):
Article 66 of the 2024 Finance Act has updated the minimum amount for the royalty on customs services for
imports as follows:

RPD Before FL 2024 After FL 2024


Minimum amount for customs TND 10 TND 20
declarations

In accordance with the provisions of Article 70 of the 2024 Finance Act, the provisions of the 2024 Finance
Act apply starting from January 1, 2024.

The same article also states that the provisions of Articles 44, 47, 55, and 66 of the 2024 Finance Act,
related to the increase of duties and taxes, do not apply to imported goods:
• Whose transport documents, issued before the entry into force of this law, justify their shipment to the
Tunisian customs territory, and
• Which are declared for direct consumption without having been placed under the regime of warehouses
or free zones.7.4 Increase in customs duties on solar panels (Article 40):
Article 40 of the 2024 Finance Act has raised the rate of customs duties to 30% with respect to the
importation of solar panels falling under tariff code Ex 85.41.

VAT and customs duties Before FL 2024 After FL 2024


VAT 7% 7%
Customs duties 10% 30%

33 | Finance Act 2024 Tax measures


CUSTOMS

7.5 Revision of customs duties on dried fruits (Article 55):


Article 55 of the 2024 Finance Act has amended the customs duties on dried fruits as follows:

Designation of Customs duties
N° position N° tarif
products Before FL 2024 Après LF 2024
Cashew nuts (with
080131
shells)
Ex 08.01
Cashew nuts (without
080132
shells)
Ex 080211 Almonds (with shells)
Ex 080212 In shell almonds
Hazelnuts ‘Corylus
Ex 080221
spp.’ (with shells) 50% 36%
In shell hazelnuts
Ex 080222
Ex 08.02 ‘Corylus spp.’
Ex 080231 Walnuts (with shells)
Walnuts (without
Ex 080232
shells)
Pistachios (with
Ex 080251
shells)
Ex 080252 In shell pistachios
Flour, semolina, and
11 063 010
powders of bananas
Flour, semolina,
Ex 11.06 15%
and powders of
11 063 090
other products from
chapter 8

In accordance with the provisions of Article 70 of the 2024 Finance Act, the provisions of the 2024 Finance
Act apply starting from January 1, 2024.
The same article also states that the provisions of Articles 44, 47, 55, and 66 of the 2024 Finance Act,
related to the increase in duties and taxes, do not apply to imported goods:
• Whose transport documents, issued before the entry into force of this law, justify their shipment to the
Tunisian customs territory, and

• Which are declared for direct consumption without having been placed under the regime of warehouses
or free zones.

7.6 Exemption from customs duties on royalties for the use of equipment,
networks, and radio frequency (Article 56):
According to Article 56 of the 2024 Finance Act, the provisions of Article 51 of the Communications Code —
requiring the payment of royalties — do not apply to the equipment of the Tunisian customs.

Finance Act 2024 Tax measures 34


8.
management and operating credits created under
Article 11 of the Prime Minister’s Decree No.
2020-6 of April 16, 2020, prescribing fiscal and
financial measures to mitigate the repercussions
of the spread of the coronavirus ‘Covid-19.’ This
amount is designated for the credit guarantee
mechanism for financing granted under the financial
restructuring program created within the framework

FINANCING of interventions of the endowment line to support


the financial restructuring of small and medium-
sized enterprises established under Article 14 of Act

MEASURES No. 2017-66 of December 18, 2017, regarding the


Finance Act for 2018.

8.1 Creation of financing lines for the 8.3 Support for small farmers in the
benefit of SMEs (Article 29): cereal crops sector (Article 25):
Article 29 of the 2024 Finance Act has established Article 15 of Decree-Law No. 2022-79 of December
two financing lines to grant medium and long-term 22, 2022, regarding the Finance Act for 2023,
credits to small and medium-sized enterprises states that ‘The State covers the difference between
(SMEs) to finance their investments. the interest rate applied to seasonal loans for cereal
An amount of TND 20 million is allocated for their farming and the average rate of the money market,
benefit, distributed as follows: up to 3 points, for loans granted by banks from their
own resources to small cereal farmers, and without
• TND 10 million from the resources of the
the margin applied by banks exceeding the rate of
Support Fund for Small and Medium-sized
3.5%.
Enterprises, created under Article 50 of Law
No. 2014-54 of August 19, 2014, on the This measure applies to seasonal loans for cereal
supplementary Finance Act for the year 2014. farming granted for the agricultural season 2022-
Its management is entrusted to the Small and 2023.
Medium-sized Enterprises Financing Bank under The conditions and procedures for benefiting from
an agreement concluded for this purpose with this measure are set by decree after obtaining the
the Ministry of Finance, specifying the conditions opinion of the Central Bank of Tunisia (BCT).’
and modalities of managing the financing line.
Decree No.2023-545 of July 20, 2023, has
• TND 10 million from the resources of the established the conditions and modalities for
National Employment Fund. Its management benefiting from the State’s coverage of the
is entrusted to the Small and Medium-sized difference between the interest rate on seasonal
Enterprises Financing Bank under an agreement loans for cereal farming and the average rate of the
concluded for this purpose with the Ministry money market, up to 3 points, for loans granted by
of Finance and the Ministry in charge of banks from their own resources to small farmers in
employment, specifying the conditions and the cereal crops sector.
modalities of managing the financing line.
This decree reserves the measure for small farmers
in the cereal crops sector who have obtained
8.2 Creation of a financing line for SME seasonal loans with a principal amount not
restructuring (Article 30): exceeding TND 50,000 and related complementary
loans, with an amount not exceeding TND 15,000.
Article 30 of the 2024 Finance Act has allocated
an amount of TND 15 million from the available Article 25 of the 2024 Finance Act extends the
resources of the credit guarantee mechanism for benefit of the measure provided by Article 15 of

35 | Finance Act 2024 Tax measures


FINANCING MEASURES

Decree-Law No.2022-79 of December 22, 2022, Equipment and Housing, and BH Bank.
regarding the Finance Act for 2023, to seasonal Article 28 of the 2024 Finance Act has extended
loans for cereal farming granted for the following the benefit of the measure for the construction of
agricultural seasons: 2022-2023, 2023-2024, and rainwater storage tanks until December 31, 2024.
2024-2025.
8.6 Strengthening financing measures
8.4 Creation of a financing line for for community enterprises (Article 32):
vulnerable and low-income categories
Under Article 29 of the Finance Act for 2023,
(Article 19):
a financing line for regional or local community
Article 19 of the 2024 Finance Act has established enterprises, as outlined in Decree-Law No. 2022-15
a financing line with an amount of TND 20 million of March 20, 2022, was created. It was intended to
from the resources of the National Employment provide credits under preferential conditions during
Fund for the benefit of vulnerable and low-income the period from January 1 to December 31, 2023.
categories. This fund is allocated to grant interest-
free credits not exceeding TND 10,000 for each The management of this line was entrusted to
credit, to finance activities in all economic sectors, the Tunisian Solidarity Bank under an agreement
during the period from January 1 to December concluded with the Ministry of Finance and the
31, 2024. The repayments are scheduled over a Ministry in charge of employment, specifying the
maximum period of 6 years, including a grace period conditions and modalities of managing the financing
of one year. line.
This line’s management is entrusted to the Tunisian Article 32 of the 2024 Finance Act has extended
Solidarity Bank under an agreement concluded for the benefit of the measure from Article 29 of the
this purpose with the Ministry of Finance and the Finance Act for 2023 until December 31, 2025.
Ministry in charge of employment, specifying the
conditions and modalities of managing the said In addition, the same article states that the
financing line. management of this line is entrusted to banks under
agreements concluded with the Ministry in charge of
finance and the Ministry in charge of employment,
specifying the conditions and modalities of its
8.5 Extension of the measure for the management.
construction of rainwater storage tanks
Finally, an additional allocation of TND 20 million
until December 31, 2024 (Article 28):
from the resources of the National Employment
Article 28 of Decree-Law No. 2022-79 of December Fund was made for the benefit of the financing line
22, 2022, regarding the Finance Act for 2023, for community enterprises.
allocated a grant of TND 2 million from the
resources of the National Housing Improvement
Fund to provide interest-free credits not exceeding
TND 20,000 for each credit to finance the
construction of rainwater collectors. This measure
was in effect from January 1 to December 31,
2023, with repayments scheduled over a maximum
period of 7 years.
The conditions and procedures for benefiting from
these credits are established through an agreement
between the Ministry of Finance, the Ministry of

Finance Act 2024 Tax measures 36


9.
59,060,628.521.
This underwriting operation is released through
the offsetting of the bank’s liabilities in favor of the
State under the Japanese credit line retroceded to
the bank on March 15, 2008, in accordance with
the provisions of Article 292 of the Commercial
Companies Code.
Notwithstanding the provisions of the current tax

SUPPORT legislation, the capital increase operation of BFPME


cannot have any tax implications for corporate
income tax.

MEASURES 9.3 Increase in the capital of the


FOR PUBLIC ‘Société Générale d’Entreprise de
Matériel et de Travaux’ through the

ENTERPRISES conversion of public liabilities (Article


43):
9.1 Abandonment of public liabilities According to Article 43 of the 2024 Finance Act,
in favor of the company ‘Ellouhoum’ the Minister of finance, acting on behalf of the
State, is authorized, within the framework of the
(Article 20): restructuring of the ‘Société Générale d’Entreprise
de Matériel et de Travaux,’ to:
According to Article 20 of the 2024 Finance Act,
the Minister of finance, acting on behalf of the • Convert the principal amount of the company’s
State, is authorized to abandon the State’s liabilities tax liability into the State’s participation in its
against the company ‘ELLOUHOUM.’ These liabilities capital, up to TND 741,096,709, as of October
are related to customs debts, up to a limit of TND 31, 2023, with the abandonment of control
4.5 million, and to a credit granted by the Public penalties, late collection penalties, and related
Enterprises Restructuring Fund, up to a limit of TND prosecution costs.
2 million. • Convert the company’s debt to the Public
Notwithstanding the provisions of current tax Enterprises Restructuring Fund in the amount
legislation, Article 20 of the 2024 Finance of TND 1,087,200,000 into a participation in its
Act specifies that the abandonment of the capital.
aforementioned State liabilities in favor of
the company ‘ELLOUHOUM’ shall have no tax Notwithstanding the provisions of the current tax
implications for corporate income tax. legislation, the application of the provisions of
this article cannot have any tax implications for
corporate income tax.

9.2 Increase in the capital of ‘BFPME’


through the conversion of public 9.4 Suspension of VAT for acquisitions
liabilities (Article 31): by the Compagnie Tunisienne de
Under Article 31 of the 2024 Finance Act, the Navigation until December 31, 2025
Minister of finance, acting on behalf of the State, (Article 42):
is authorized to subscribe to the increase in the
capital of the Small and Medium-sized Enterprises According to Article 42 of the 2024 Finance Act,
Financing Bank (BFPME) up to an amount of TND Compagnie Tunisienne de Navigation benefits from

37 | Finance Act 2024 Tax measures


SUPPORT MEASURES FOR PUBLIC ENTERPRISES

the suspension of VAT for import and local acquisition operations of equipment, materials, spare parts,
products, and services necessary for its activity, starting from January 1, 2024, until December 31, 2026.

This benefit is granted for local acquisitions based on a certificate of general or specific VAT suspension, as
applicable, issued by the competent tax authority.

9.5 Suspension of VAT for coffee and tea imported by the Office du Commerce de
la Tunisie (Article 21):
Article 21 of the 2024 Finance Act provides for the suspension of VAT for the following products:

N° of position Designation of products


Ex 09.01 Coffee
Ex 09.02 Tea

These provisions regarding the suspension of VAT apply to tea and coffee imported by Office du Commerce
de la Tunisie.

Finance Act 2024 Tax measures 38


10.
OTHER MEASURES
10.1 Regularization of the situation of
construction workers aged between 45 and 55
(Article 12)
According to Article 12 of the 2024 Finance Act, the State
undertakes to regularize the situation of construction workers
who have exceeded the age of 45 and have not reached the
age of 55 by hiring them. This regularization will occur in three
phases, starting from 2024 until 2026, and it is possible to
grant a departure allowance for those who choose voluntary
departure.

10.2 Strengthening the resources of the


Biological Rest Fund (Article 17)
According to Article 17 of the 2024 Finance Act, the ‘Biological
Rest Financing Fund in the Fisheries Sector’ is funded by:
• the tax provided for in Article 2 of Law No. 2009-17 of
March 16, 2009, related to the regime of biological rest in
the fisheries sector and its financing,
• resources from the annual national share of tuna fishing,
the withholding tax of 40% of the profits of vessels holding
a tuna fishing permit, the withholding tax of 40% of the
profits from tuna farming, fattening, and export cages.
These additional resources from tuna fishing and export
are intended for small sailors on trawlers and coastal
fishing boats, as compensation for damages caused by
tuna. The method of their collection will be determined by
a joint decree of the Minister of Finance and the Minister
responsible of Fisheries.
• donations and subsidies granted to the Fund by individuals
and legal entities,
• any other resources that may be allocated to the Fund in
accordance with current legislation.

39 | Finance Act 2024 Tax measures


OTHER MEASURES

10.3 Strengthening the resources of the Fund


for compensation of agricultural damages
caused by natural disasters (Article 18):
Article 18 of the 2024 Finance Act has strengthened the
resources of the Fund for compensation of damages caused
by natural disasters by allowing the allocation of domestic
and foreign donations and aid to its benefit, as well as any
resources that can be allocated to it.
Furthermore, Article 18 of the 2024 Finance Act has
allocated 20% of the resources of the Fund for the
development of competitiveness in the agricultural and
fisheries sector for the benefit of the Fund for compensation
of damages caused by natural disasters.

10.3 Establishment of a special treasury Fund


‘Judicial Jurisdiction Development Support
Fund’ (Article 13):
Article 13 of the 2024 Finance Act has created a special
treasury Fund titled ‘Judicial Jurisdiction Development
Support Fund’ within the registers of the General Treasury of
Tunisia to contribute to the financing of programs aimed at
improving the judicial order service.
The Minister of Justice is the administrator of this fund. The
expenses of the fund are of an estimated nature.
The interventions of the fund will be determined by decree.
The Judicial Jurisdiction Development Support Fund is
financed by:
• The tithes in addition to fines and financials penalties,
as provided in the decree of June 17, 1954, effectively
collected.
• A tax on orders on request and orders to pay, applied
at the rate of TND 10, on applications for requests for
orders, orders to pay, and retraction requests. This tax
is paid by a receipt in accordance with the provisions
of Article 128 quater of the CDET. The said receipt is
attached to the order request or order to pay or the
request for retraction.
• 30% of the fees collected in return for the procedures
provided for in Table No. 1 of Article 1 of Presidential
Decree No. 2022-298 of March 28, 2022, fixing the
amounts of fees for services provided by the National
Center for Business Register and the modalities of their

Finance Act 2024 Tax measures 40


recovery. 10.5 Establishment of a national Fund
• Resources from royalties for services rendered for educational system reform (Article
by judicial structures that can be allocated to the 15):
fund in accordance with existing legislation or
regulations. Article 15 of the 2024 Finance Act has established a
‘National Fund for Educational Reform.’
• Donations and specific resources granted for
the benefit of judicial Courts in accordance with This fund is financed by:
existing legislation or regulations. • Donations from Tunisians both locally and
abroad,
10.4 Creation of a special treasury Fund • A percentage of 0.5% of the profits of private
for urban transport financing (Article educational institutions: schools, high schools,
universities, and training centers,
14):
• A percentage of 0.25% of the profits of oil
Article 14 of the 2024 Finance Act has established companies, insurance companies, banks, large
within the registers of the General Treasury of commercial surfaces, and pharmacies.
Tunisia a Special Treasury Fund called ‘Urban
• Expenses related to educational reform
Transport Financing Fund.’ This fund supports the
operations are carried out through this Fund,
State’s efforts in financing certain activities for the
including:
care and maintenance of urban public transport
infrastructure and equipment. It specifically • Diagnostic activities of the educational system,
contributes to financing micro-investments in the • Engineering activities for alternative programs
field of urban transport and studies related to and methods,
national policies on urban transport.
• Upgrading of educational spaces to enable the
achievement of the objectives of educational
The Minister of Transport is the administrator of
reform.
the fund, and the expenses of the fund are of an
estimated nature. The administrator of this Fund is the President
of the High Council of Education. This mission is
The intervention modalities of the fund will be temporarily assigned to the Minister of Education
determined by decree. until the appointment of a president of the High
Council of Education.
The Urban Transport Financing Fund is financed by:
• A percentage of 10% of the revenue from
10.6 The transfer of frozen amounts to
existing taxes applied to administrative the accounts of the General Treasury of
procedures related to vehicle registration and Tunisia (Article 65)
transport authorizations,
Article 65 of the 2024 Finance Act introduces
• Donations granted to the fund within the
measures regarding the transfer of frozen amounts
framework of projects related to these
to the accounts of the General Treasury of Tunisia,
interventions,
under the following conditions:
• Any other resources that may be allocated to
it in accordance with existing legislation or Obligation to declare and transfer frozen
regulations. funds from January 1, 2024:
Banks are required to report to the General Treasury
of Tunisia, in the first 15 days of each calendar
quarter, the amounts held in accounts opened

41 | Finance Act 2024 Tax measures


OTHER MEASURES

within their bank belonging to individuals of Tunisian Sanctions


nationality, organizations, and entities established in
Any institution subject to the application of
accordance with Tunisian legislation and listed in the
the above provisions is liable to a fine equal to
freezing decisions in force in the previous quarter.
10% of the frozen amounts not transferred if it
This must be done according to a model established
fails to declare these amounts or declares them
by the administration, and these amounts are to be
inaccurately or incompletely or if it declares them
deposited into the current account of the Treasury
without transferring these amounts to the state
at the Central Bank of Tunisia (BCT) within the same
treasury.
aforementioned period.
The finding of this offense and the application of
The collected amounts are deposited into a specific
the aforementioned fine are carried out by the
item for Treasury operations, created in the records
supervisory and control authority to which the
of the General Treasury of Tunisia.
institutions subject to the application of these
These provisions apply to the accounts of provisions belong.
individuals, organizations, and entities mentioned
above and listed in the freezing decisions in force
from January 1, 2024. Special cases under Articles 45 and 104 of
Obligation to declare and transfer funds the Organic Law No. 2015-26 of August 7,
frozen before January 1, 2024: 2015, on anti-terrorism and anti-money
laundering:
Banks are required to report to the General Treasury
of Tunisia the amounts held in accounts opened The above provisions are applicable, subject to the
within their banks belonging to individuals of cases provided for in Articles 45 and 104 of the
Tunisian nationality, organizations, and entities Organic Law No. 2015-26 of August 7, 2015, on the
established in accordance with Tunisian legislation fight against terrorism and money laundering.
and listed in the freezing decisions in force as In this regard, upon receiving an order to lift the
of December 31, 2023. This declaration must freeze on specific amounts to pay necessary or
be made according to a model established by exceptional expenses, the bank must notify the
the administration, and these amounts are to be General Treasury of Tunisia within a maximum of
deposited into the current account of the Treasury 5 days from the date of receiving this order. The
at the BCT, within a maximum period ending on April General Treasury of Tunisia must transfer the
15, 2024. specified amounts to the account of the person
The amounts collected for this purpose are whose funds were frozen.
deposited into a specific item for Treasury However, in cases where the freeze is based
operations, created in the records of the General on a resolution from competent international
Treasury of Tunisia. organizations, the order must include the
Lifting freeze notification of these organizations and their non-
opposition within the legal deadlines stipulated in
The transfer of funds is temporary until the lifting Article 104 of the Organic Law No. 2015-26 of
of the freeze measure on the relevant account, August 7, 2015, on the fight against terrorism and
provided that the banks notify the General money laundering. In this case, the bank must notify
Treasury of Tunisia with proof of the lifting of the the General Treasury of Tunisia within a maximum of
freeze within a maximum of 5 days from the date 5 days from the date of receiving this order.
of receiving the order to lift the freeze. This is
performed to return the frozen amounts to the
accounts opened within the banks.

Finance Act 2024 Tax measures 42


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