New income tax on foreign e-commerce platforms without a business presence in Côte d'Ivoire (Article 33)

Until now, a foreign digital platform (marketplace, social network, search engine, cloud service, content or online gaming platform) with no business presence in Côte d'Ivoire — no premises, no server, no representative — escaped corporate income tax (BIC), even while generating real turnover from Ivorian customers. Article 33 of the tax annex to Finance Law No. 2025-987 of December 19, 2025 puts an end to this situation.

Who is now affected?

A foreign digital services platform now falls within the scope of corporate income tax once two conditions are met: it has no business presence in Côte d'Ivoire, and it generates annual turnover, all taxes included, of at least 50,000,000 FCFA from customers established in Côte d'Ivoire. The activities covered mirror the list already used for VAT on digital platforms (Article 7 of the 2022 tax annex): online advertising, sale of data, marketplaces, digital content, online gaming, cloud services, social networks, search engines, and so on.

Who remains outside the scope?

Three situations remain outside this regime: platforms that have a genuine physical presence in Côte d'Ivoire (they then fall under the ordinary BIC regime, not this flat-rate regime); those whose Ivorian turnover stays below the 50 million FCFA threshold; and those whose country of residence has signed a tax treaty with Côte d'Ivoire that makes the right to tax profits conditional on the existence of a "permanent establishment." By definition, a permanent establishment requires a physical presence, which rules out purely digital platforms. For an international group, this is the first thing to check: the applicable tax treaty may neutralize this new Ivorian regime, and the analysis must be done case by case.

How taxable profit is calculated

The calculation method is a flat-rate one that departs from ordinary rules: taxable profit is set at 10% of the turnover generated in Côte d'Ivoire (a 90% allowance meant to cover expenses), then taxed at the standard rate of 30%. The effective tax rate therefore works out to 3% of turnover:

Corporate income tax = (Turnover × 10%) × 30% − BNC withholding tax (Article 92 of the General Tax Code)

If a withholding tax on non-commercial profits (BNC, under Article 92 of the General Tax Code) has already been deducted from amounts paid to the platform, it is credited against this tax, though it never generates a refundable tax credit.

Filing and payment

Platforms concerned must file their results online no later than June 30 of the year following the one in which the Ivorian turnover was generated, following a simplified, fully digital procedure. Payment of the tax is due on the same date, also made electronically.

Stronger, public penalties

Beyond the standard penalties already in force (late-payment surcharges, suspension of platform access from Ivorian territory), the 2026 tax annex introduces a new and deterrent sanction: publishing, on the DGI's website and any other national or international media accessible to the public, a list of non-compliant foreign platforms. Three deadlines punctuate this publication each year: March 31 for unregistered platforms, October 31 for those that have not filed or paid the corporate income tax due, and the last day of the month following each calendar quarter for those that have not filed or paid the VAT due.

ANKHURA CONSEIL's advice: If your group operates a digital platform serving Ivorian customers, the first step is to precisely measure the turnover generated in Côte d'Ivoire against the 50 million FCFA threshold, then check whether an international tax treaty neutralizes the regime or not. ANKHURA CONSEIL supports foreign groups through this analysis and through bringing their filings into compliance.