Côte d’Ivoire stops treating online platform services as exports for VAT refunds

What changed in detail

Article 24 of the fiscal annex to Loi de finances n° 2023-1000 du 18 décembre 2023 (the budget law for 2024) amends article 357-13 of Côte d’Ivoire’s Code Général des Impôts.

Article 357-13 treats as exports the services covered by article 352 that are not used in Côte d’Ivoire and are performed for businesses with no professional establishment there, when they are not taxable in Côte d’Ivoire. According to the annex’s statement of reasons, these included the services of online service platform operators covered by articles 352-6 and 352-7, which gave those operators a right to refund of the resulting TVA credit.

The statement of reasons says the aim of article 7 of the 2022 fiscal annex had been to tax these platform operations, not to treat them as exports or let them generate refundable TVA credits.

The text adds at the end of article 357-13 the words “à l’exclusion des opérations citées aux points 6 et 7 dudit article”. From 1 January 2024, platform services under points 6 and 7 of article 352 are no longer operations assimilated to exports.

What it means

The exclusion is still in force; the 2025 Finance Law annex does not revisit article 357-13. The effect is on cash, not on scope: platform operators remain within Ivorian TVA, but their services can no longer be presented as exports to build a TVA credit and claim it back. An operator that had relied on refunds of credits generated through export treatment lost that route from the 2024 budget year.