Mobile Money payments by businesses: the end of the 250,000-franc deductibility cap (Article 7)

Few provisions in the 2026 Finance Law tax annex affect as many businesses as Article 7: it clarifies the tax treatment of payments made via Mobile Money, an issue whose ambiguity created a real risk in the event of an audit.

The problem before the reform

Before the 2026 tax annex, the tax treatment of Mobile Money payments was not clearly defined. In practice, during audits, the tax authority sometimes treated these payments as cash payments. Yet Articles 18 bis and 373 of the General Tax Code cap, respectively, the deduction of expenses (for corporate income tax purposes) and of the corresponding VAT at 250,000 francs per cash payment: beyond that amount, in cash, the expense is not deductible and the VAT is not recoverable.

What Article 7 changes

Going forward, all payments made through an approved Mobile Money platform (Orange Money, MTN Money, Moov Money, Wave, etc.) are classified as electronic payments, not cash payments, regardless of amount. Direct consequence: they can no longer be subject to the 250,000-franc deduction cap under Articles 18 bis and 373 of the General Tax Code, for either corporate income tax or VAT purposes.

The conditions for deductibility remain unchanged

Removing the cap does not exempt taxpayers from the ordinary conditions for deduction. To be deductible, whether as an expense or for VAT, Mobile Money payments must still meet the conditions of Articles 18 et seq. and 362 et seq. of the General Tax Code: the expense must be incurred in the direct interest of the business and relate to its normal operations; for VAT, the purchases concerned must be used exclusively for manufacturing and selling goods subject to the tax, or for export.

The point to watch: traceability when an intermediary is involved

The DGI has also clarified a case that comes up frequently in practice: when a business A pays for a service rendered by a provider B by handing cash to an electronic payment intermediary, who is then responsible for paying B on A's behalf, business A is considered to have paid for the service electronically, provided the receipt issued by the intermediary clearly identifies business A as the one who handed over the cash, provider B as the recipient, and the service concerned. The same applies when the business holds a Mobile Money account directly, from which it pays the expense. On the other hand, if this link between the cash handed over and the payment for the service does not appear clearly on the receipts or invoices issued by the intermediary, the service is deemed to have been paid in cash, and therefore loses its right to deduction if the 250,000-franc limit is exceeded.

ANKHURA CONSEIL's advice: Removing the cap is a genuine simplification, but it shifts the risk toward documentary proof. Businesses that pay their suppliers through an electronic payment intermediary should make sure that every receipt clearly identifies the payer, the beneficiary and the service paid for. Otherwise, the risk of reclassification as a cash payment remains very real during an audit. ANKHURA CONSEIL helps clients secure their internal Mobile Money payment procedures.