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Guinea

Country Name: Republic of Guinea
Currency: Guinean Franc (GNF)
Primary Tax Authority: National Directorate of Taxes (Direction Nationale des Impôts, DNI)
Key Legislation:

  • General Tax Code
  • Value Added Tax (VAT) Law
  • Customs Code
  • Investment Code
  • Tax Procedures Law

Fiscal Authority Allocation

Centralized Fiscal System:
Guinea operates a centralized tax system, with the National Directorate of Taxes (DNI) responsible for administering and collecting taxes, including corporate income tax (CIT), personal income tax (PIT), value-added tax (VAT), and customs duties.

Corporate Income Tax (CIT)

Standard Rate: 35%
Guinea imposes a corporate income tax rate of 35% on resident companies and non-resident companies with a permanent establishment in the country.

Corporate Forms and Taxation:

  1. Resident Companies: Taxed on worldwide income.
  2. Non-Resident Companies: Taxed only on Guinea-sourced income.

Exemptions and Incentives:

  • Investment Incentives: The Investment Code offers tax holidays, customs duty reductions, and VAT exemptions for companies investing in sectors such as mining, agriculture, energy, and infrastructure.
  • Special Economic Zones (SEZs): Companies operating in SEZs benefit from CIT reductions, customs duty exemptions, and VAT relief for a specified period.

Goods and Services Tax (GST) / Value-Added Tax (VAT)

Standard Rate: 18%
Guinea imposes VAT at a standard rate of 18% on most goods and services. VAT applies to both domestic production and imports.

Exemptions:
Certain essential goods and services, such as healthcare, education, and financial services, are VAT-exempt. Exports are zero-rated, allowing businesses to claim VAT refunds on inputs used in producing export goods.

Personal Income Tax (PIT)

Progressive Rates:
Guinea applies a progressive personal income tax system to residents’ worldwide income and non-residents’ Guinea-sourced income.

Resident Tax Rates for 2023 (Annual Income):

  • Up to GNF 1,000,000: 0%
  • GNF 1,000,001 to GNF 3,000,000: 10%
  • GNF 3,000,001 to GNF 5,000,000: 20%
  • Above GNF 5,000,000: 35%

Non-Resident Tax Rate:
Non-residents are taxed at a flat rate of 15% on Guinea-sourced income.

Deductions and Allowances:
Taxpayers may deduct social security contributions, pension contributions, and certain personal expenses such as healthcare costs and charitable donations from taxable income.

Additional Mandatory Contributions

Social Security Contributions:
Employers and employees must contribute to Guinea’s social security system, which provides pensions, healthcare, and other social benefits.

  • Employer Contribution: 18% of gross salary.
  • Employee Contribution: 5% of gross salary.

Withholding Taxes

  • Dividends: 10% for residents, 15% for non-residents
  • Interest: 15% for residents, 15% for non-residents
  • Royalties: 15%
    Guinea imposes withholding taxes on payments to non-residents, including dividends, interest, and royalties. These rates may be reduced under Guinea’s double taxation agreements (DTAs).

Transfer Pricing Rules

Guinea follows the arm’s-length principle for related-party transactions. Companies must ensure that cross-border transactions between related entities are conducted at market value. Transfer pricing documentation is required for multinational companies engaged in related-party transactions.

Special Tax Regimes

  • Special Economic Zones (SEZs): Companies operating in Guinea’s SEZs benefit from tax holidays, customs duty exemptions, and VAT relief. These zones are designed to attract foreign direct investment in sectors such as manufacturing, mining, and energy.
  • Investment Incentives: The Investment Code provides tax holidays, reduced CIT rates, and customs duty exemptions for companies investing in sectors such as agriculture, renewable energy, and infrastructure.

Other Taxes

  • Customs Duties: Guinea applies customs duties on imported goods, with rates ranging from 5% to 20%, depending on the type of goods. Essential goods and raw materials may qualify for reduced or zero customs duties.
  • Excise Taxes: Excise taxes are levied on alcohol, tobacco, petroleum products, and luxury items.
  • Property Tax: Local authorities in Guinea impose property taxes on land and buildings based on their assessed value.

Double Taxation Agreements (DTAs)

Guinea has signed several double taxation agreements (DTAs) with countries such as France, Morocco, and members of the Economic Community of West African States (ECOWAS). These agreements help reduce withholding taxes on cross-border income and prevent the double taxation of income earned in Guinea and other jurisdictions.

Local Taxes

Local governments in Guinea may impose property taxes, business license fees, and local service levies. However, most major taxes, including CIT, PIT, and VAT, are centrally administered by the National Directorate of Taxes (DNI).

Compliance and Reporting

Annual Filing:
Corporate tax returns must be filed within three months following the end of the financial year. Personal income tax returns are generally due by March 31st. VAT returns are filed monthly or quarterly, depending on the size of the business.

Penalties for Late Filing:
Penalties for non-compliance or late filing include fines and interest on unpaid taxes. The DNI charges interest at 1.5% per month on overdue taxes, with additional penalties for tax evasion or underreporting.

Recent Developments

Mining Sector Focus:
Guinea’s mining sector, particularly in bauxite and iron ore, continues to attract significant foreign investment. The government provides tax incentives for mining companies, including CIT reductions, VAT exemptions, and customs duty relief.

Agriculture and Renewable Energy:
Guinea is promoting investment in agriculture and renewable energy through tax incentives such as CIT holidays, VAT exemptions, and reduced customs duties on agricultural and renewable energy equipment.

Digital Taxation and E-Government:
Guinea is implementing digital tax measures aimed at improving tax compliance and administration. The government is also expanding electronic tax filing systems to simplify tax reporting for businesses and individuals.

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