Professional Documents
Culture Documents
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
6. AMNESTY P 28
7. CUSTOMS P 32
8.FINANCING MEASURES P 35
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.
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.
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:
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
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.
Other vehicles,
equipped solely with
Ex 87.03 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.
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.
Article 22 of the 2024 Finance Act provides for the suspension of VAT for the following products intended
for patients suffering from gluten intolerance:
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.
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:
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.
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:
EX04.01
EX04.02 Milk cream 2
EX04.03
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.
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.
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:
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).
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.
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:
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.
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 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
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 .
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
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
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.
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.
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.
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.
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.
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.
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.
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
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
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:
These provisions regarding the suspension of VAT apply to tea and coffee imported by Office du Commerce
de la Tunisie.
© 2024 EY Tunisia
Contact :
Email: tunisoffice@tn.ey.com
Tel: +216 70 749 111
Fax: +216 70 749 045
Faez Choyakh
Tax Partner
faez.choyakh@tn.ey.com