Côte d’Ivoire makes factoring operations expressly subject to TVA from 1 January 2026

What changed in detail

Article 5 of the fiscal annex to Côte d’Ivoire’s Loi de finances n° 2025-987 du 19 décembre 2025 (the budget law for 2026) adds a new dash at the end of article 344 of the Code général des Impôts, the list of operations subject to TVA: “les opérations d’affacturage” (factoring operations).

The statement of reasons explains the change. Factoring lets a business transfer its commercial receivables to a financial body to obtain immediate cash and to delegate their management. Under article 3 of Loi n° 2023-423 du 22 mai 2023 on factoring in Côte d’Ivoire, it is carried on by credit institutions and decentralised financial systems (SFD). Because of the status of those entities, the turnover-tax treatment of factoring had been interpreted in different ways, which caused disputes. As factoring deals only with commercial receivables, the annex proposes to make it expressly subject to TVA. The expected gain is estimated at 2.9 billion francs CFA.

The annex has no separate commencement clause; it applies with the 2026 budget year, from 1 January 2026.

What it means

The rule is in force for 2026 and no later instrument recorded here changes it. It settles the dispute in the tax authority’s favour: factoring fees and charges carry TVA whoever the factor is, even where the factor is a bank or SFD whose other financial operations are treated differently.

For businesses that factor their receivables, the TVA on the factor’s charges is an extra cost unless they can deduct it under the normal rules. Factors need to invoice TVA on these operations and review contracts priced before 2026.