Côte d’Ivoire narrows the VAT exemption for natural foods to a list of staples

What changed in detail

Article 1 of the fiscal annex to Côte d’Ivoire’s Loi de finances n° 2023-1000 du 18 décembre 2023 (the budget law for 2024) rewrites the first paragraph of article 355-9 of the Code Général des Impôts.

Before the change, the article exempted from TVA all natural food products consumed in Côte d’Ivoire, whatever the product. The annex’s statement of reasons notes that this covered luxury and non-essential products as well as staples, and that it did not conform to UEMOA Directive n° 02/98/CM/UEMOA, which exempts only the basic natural foods listed in its annex.

The new text limits the exemption to sales and supplies of unprocessed staple foods:

• maize, millet, sorghum, fonio, wheat, rice (except luxury rice) and other cereals;
• cassava, sweet potato, yam, potato, taro and other tubers and roots;
• beans, soya, sesame, groundnuts, peas and other legumes;
• onion, tomato, aubergine, okra, chilli and other vegetables;
• eggs in shell;
• fresh meat and offal, except luxury meat;
• unprocessed fish (fresh, smoked, salted or frozen), except luxury fish; and
• unprocessed milk.

The list of luxury products excluded from the exemption is set by joint order of the ministers in charge of the budget and of animal and fishery resources. The annex has no separate commencement clause; it applies with the 2024 budget year, from 1 January 2024.

What it means

The restriction is still in force, but the list has since been adjusted. Article 1 of the fiscal annex to the 2025 Finance Law (Loi n° 2024-1109) widened the meat item to all unprocessed meat and offal except luxury meat, added bananas, oranges and other locally produced natural fruits and food salt, and added the agriculture and trade ministers to the order that defines luxury products. Article 18 of the fiscal annex to the 2026 Finance Law (Loi n° 2025-987 du 19 décembre 2025) then narrowed the fruit item again by excluding dessert bananas (“à l’exclusion de la banane dessert”) from the exemption for locally produced fruits.

The practical point is that “natural” no longer settles the question. A food supplier has to check the product against the list in article 355-9, and for rice, meat and fish against the luxury-product order, before treating a sale as exempt.