Tunisia Loi n° 2024-48 — Loi de Finances 2025 Article 38 — Contribution Conjoncturelle on Large Enterprises

Mechanism

Article 38 of Loi n° 2024-48 du 9 décembre 2024 creates a Contribution Conjoncturelle — a cyclical surcharge on corporate profits for fiscal year 2025. The measure operates as follows:

• Who pays: Legal entities subject to the Tunisian corporate income tax (IS) at the standard 15% rate whose gross revenue (hors taxes) for 2023 exceeded 20 million dinars. Sectors taxed at the higher 35% rate — banks, insurance companies, telecommunications operators, and hydrocarbons concessionaires — are by definition excluded from this instrument, as they do not meet the 15%-rate precondition.
• Rate: 2% of the taxable profits used as the IS assessment base; minimum payment of 1,000 dinars regardless of profit level.
• Non-deductibility: The contribution cannot be deducted from the corporate income tax base — it is a net additional fiscal charge on top of the IS liability, not a deductible expense.
• Administration: Controlled and disputed under the same procedures as the IS (Impôt sur les Sociétés), administered by the Direction Générale des Impôts (DGI).
• Temporal scope: Explicitly limited to fiscal year 2025; the law contains no renewal clause.

The 20-million-dinar turnover threshold targets the cohort of large manufacturing, agribusiness, logistics, tourism, and business-services groups that benefited from strong post-COVID recovery margins. The instrument is architecturally analogous to the European temporary solidarity contributions on energy-sector windfall profits (Council Regulation (EU) 2022/1854) but applied across a broader sector footprint with lower rates.

Political-economy context

The Contribution Conjoncturelle is the most salient revenue-mobilisation instrument in LF2025. Tunisia's fiscal space has been severely constrained since the IMF EFF programme (approved October 2022 for SDR 1.9 billion) entered a de facto stall in 2023, after the President declined to accept programme conditionality on subsidy reform and public-enterprise restructuring. With external financing compressed and domestic borrowing approaching BCT limit thresholds, the government turned to a one-year emergency levy on the profitable segment of the private sector as an off-programme revenue substitute.

The LF2025 parliamentary process was completed 2–4 December 2024 under the post-2021 constitutional framework, with the law promulgated by President Kais Saïed on 9 December 2024.

Downstream implications

• Large non-financial Tunisian corporates: The measure principally affects manufacturing conglomerates (Poulina, Carthage Cement), logistics operators, and export-platform services firms that cleared the 20 MDT threshold in 2023 at the 15% CIT rate.
• Foreign-controlled subsidiaries at 15% CIT rate: Export-oriented manufacturing JVs (automotive-component, textile, electronics) with Tunisian registered operations face the same levy.
• Banking/telecom/insurance/hydrocarbons excluded: Art. 38 does not reach the 35%-CIT-rate sectors; these sectors bear heavier statutory fiscal burdens through separate channels.
• IMF negotiation optic: The conjunctural contribution substitutes for deeper structural fiscal reform that the IMF EFF conditionality required. It may improve the 2025 budget headline but does not address the subsidy bill or SOE transfer exposure — the core IMF sticking points.
• Investment-climate signal: A one-year emergency levy is generally tolerated by foreign investors; renewal in LF2026 would signal fiscal extraction as a durable strategy rather than a transitory measure.

LF-year-on-year arc

The two instruments are structurally complementary: LF2024 Art. 33 is an investment-attraction incentive for new entrants; LF2025 Art. 38 is a fiscal-extraction measure on the existing large-enterprise stock — reflecting the tension between Tunisia's investment-promotion objectives and its fiscal-financing constraints under IMF-EFF stalemate.