Côte d’Ivoire makes VAT mandatory for public transport companies under the real regime

What changed in detail

Article 3 of the fiscal annex to Loi de finances n° 2023-1000 du 18 décembre 2023 (the budget law for 2024) changes how Côte d’Ivoire’s TVA treats public transport.

Before the change, article 355-8 of the Code Général des Impôts exempted transport activities from TVA, apart from deliveries of materials extracted in Côte d’Ivoire including transport and specialised transport such as cash convoying, towing and express document and parcel delivery. Public transport companies under a real taxation regime could opt into TVA under article 348.

The annex’s statement of reasons says the exemption did not conform to UEMOA Council decision n° 02/CM/2019/UEMOA of 21 June 2019. The text then:

• adds to article 344 of the CGI, among persons liable to TVA, “les entreprises de transport public de personnes et/ou de marchandises, relevant d’un régime réel d’imposition”;
• deletes the option in article 348 and the transport exemption in article 355-8.

The statement of reasons identifies the companies concerned as those whose annual turnover including all taxes exceeds CFA 200 million. The change applies with the 2024 budget year, from 1 January 2024.

What it means

The obligation is still in force. The 2025 Finance Law (Loi n° 2024-1109, Article 1) made what it called technical corrections to the measure: it allows full deduction of the TVA on fuel used in public transport vehicles of real-regime companies, and makes TVA on vehicles those companies acquire for public transport deductible.

For operators above the threshold, TVA is no longer a choice to weigh but a standing obligation: fares carry TVA, returns are due, and input tax becomes recoverable. Smaller operators outside the real regime remain outside the measure.