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Luca Pacioli, Andersen Global’s Collaborating Firm in Tunisia, joins the North Africa meeting in Morocco to strengthen regional collaboration for multinational clients.

Tunisia generally follows the principle of freedom of investment, allowing foreign investors to establish and own companies in Tunisia, subject to the specific rules governing the relevant economic activity. Certain commercial activities remain subject to the foreign-investor regime and may require a carte de commerçant or other regulatory approval.

Tunisia's transfer pricing regulations require related-party transactions to comply with the arm's-length principle. Mandatory filing applies to companies with cross-border intercompany transactions exceeding TND 200 million turnover and transactions over TND 100,000.

Tunisia's standard CIT rate increased to 20% under Finance Law 2025. Companies must file annual returns and make three provisional instalment payments.

Foreign companies carrying out activities in Tunisia must understand when they create a Permanent Establishment (PE). The analysis starts with Tunisian domestic law (Article 2 of the Tax Code and Note Commune n°2/2015), then considers applicable Double Tax Treaties.

Foreign companies entering Tunisia must choose between a subsidiary (separate legal entity) or a branch (extension of the parent company). Each structure has distinct tax, legal, and operational implications.