21 February 2018

Algeria's Tax Authority clarifies services export definition for CIT exemption purposes

On 8 February 2018, Algeria's Tax Directorate (DGI) published a Circular
(N°02/MF/DGI/DLRF/LF18) with respect to Article 6 of the 2018 Finance Act, which amended Article 138 of the Direct Tax Code. The Circular clarifies the definition of "services export" for purposes of the Corporate Income Tax (CIT) exemption.

The activity of services export is now defined as "a service rendered from Algeria that is intended to be consumed in a foreign country, by a beneficiary, either in that same foreign country or in another foreign country."

Consequently, and in order to benefit from the CIT exemption, the transaction must generate revenue in a foreign currency. It also cannot relate to a service rendered or exploited in Algeria.

This clarification is likely to impact a number of companies which have been working in Algeria under a model that based the exemption on the foreign currency revenue even if the services were not actually "exported" and related to local transactions, most notably in the life & sciences, engineering and advisory sectors.

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CONTACTS

For additional information with respect to this Alert, please contact the following:

Ernst & Young Tax & Legal Algérie, Head of Africa desk – Maghreb and Francophone Africa and Head of Algeria Tax Practice, Alger

  • Bruno Messerschmitt
    bruno.messerschmitt@ey-avocats.com

Ernst & Young Tax & Legal Algérie, International Tax Services, Alger

  • Yacine Deramchia
    yacine.deramchia@dz.ey.com

Ernst & Young Tax & Legal Algérie, Business Tax Advisory, Alger

  • Halim Zaidi
    halim.zaidi@dz.ey.com

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ATTACHMENT

PDF version of this Tax Alert

 

Document ID: 2018-5306