Côte d’Ivoire abolishes two VAT exemptions: deep-water oil purchases and CGA fees

What changed in detail

Article 43 of the fiscal annex to Côte d’Ivoire’s Loi de finances n° 2024-1109 du 18 décembre 2024 (the budget law for 2025), headed “Mesures de rationalisation des exonérations fiscales”, repeals a set of exemptions across several taxes.

For TVA, paragraph 4 of the text repeals two items of article 355 of the Code général des Impôts:

• alinéa 44: direct local purchases of goods specific to deep-water petroleum exploration and production operations by oil companies, subject to approval by the Minister of Finance on the opinion of the indirect-tax exemption commission;
• alinéa 56: contributions paid by members of approved management centres (Centres de Gestion agréés, CGA).

The statement of reasons presents the repeal as a continuation of the exemption rationalisation in the 2021 and 2022 fiscal annexes and of alignment with UEMOA Directive n° 02/98/CM/UEMOA. The same article also repeals exemptions outside TVA (articles 4-A)-10, 151-19 and 219 of the CGI).

The annex has no separate commencement clause; it applies with the 2025 budget year, so both operations are subject to TVA at the 18% standard rate from 1 January 2025.

What it means

The repeal is in force and no later instrument recorded here restores either exemption. Local suppliers to deep-water oil projects invoice TVA on these goods from 2025; the oil company can recover it only under the normal deduction rules. For CGA members, the membership fee now carries TVA, which is a straight cost for members that cannot deduct it.