Tunisia Wealth Tax: A Technical Analysis of Circular Note No. 13/2026

The publication of Circular Note No. 13/2026 by the Tunisian General Directorate of Tax Studies and Legislation (DGELF) provides much-needed guidance on the Wealth Tax introduced by Article 88 of the 2026 Finance Act.

While the legislation established the general framework of the new Wealth Tax regime, several practical and technical issues remained unresolved. Circular Note No. 13/2026 clarifies a number of important aspects regarding the taxable base, valuation methodologies, exemptions and the treatment of financial assets.

Financial Assets Are Explicitly Included in the Taxable Wealth Base

One of the most significant clarifications concerns the treatment of securities and financial investments.

The Circular confirms that shares, equity interests, bonds and other financial rights qualify as movable assets and therefore form part of the taxable wealth base.

This interpretation considerably broadens the scope of the Wealth Tax beyond real estate holdings and extends its application to financial and entrepreneurial wealth.

Professional Shareholdings May Qualify for Exemption

The Circular introduces an important exemption mechanism for qualifying business holdings.

According to the administrative position, shares and equity interests may be treated as professional assets where the taxpayer and his or her minor children directly own at least 50% of the company's capital.

This clarification significantly reduces the impact of the Wealth Tax on founders, family-owned businesses and controlling shareholders.

Rental Properties May Benefit from Professional Asset Treatment

The Circular further states that rental properties may qualify as professional assets where rental income is properly reported for tax purposes.

This interpretation provides a more business-oriented approach to income-generating real estate investments and may substantially reduce taxable wealth in certain situations.

Valuation of Unlisted Shares: A Key Compliance Challenge

The Circular outlines several valuation approaches that may be used by the tax administration, including:

• adjusted book value;

• liquidation value;

• comparable transactions;

• expert valuation methods;

• administrative reassessment procedures.

For family-owned businesses and private holding companies, valuation issues are likely to become one of the most sensitive areas of future tax audits.

Worldwide Wealth Principle Confirmed

The Circular also confirms that Tunisian tax residents are subject to Wealth Tax on their worldwide assets.

As a result, foreign real estate, foreign securities portfolios, overseas investments and international business holdings must generally be considered when determining taxable wealth.

Double tax treaty provisions remain essential in assessing the final tax exposure of internationally mobile individuals.

Threshold Effect and Potential Controversies

The administrative interpretation confirms that the applicable rate applies to the entire taxable wealth base rather than only to the excess portion.

Accordingly:

• wealth between TND 3 million and TND 5 million is taxed at 0.5%;

• wealth exceeding TND 5 million is taxed at 1%.

This creates a significant threshold effect that may generate future legal and tax controversies.

Remaining Uncertainties

Despite the guidance provided by Circular Note No. 13/2026, important questions remain unresolved, including:

• taxation of crypto-assets;

• indirect shareholdings through holding structures;

• usufruct and bare ownership arrangements;

• trusts and foreign foundations;

• valuation of certain international private investments.

These issues may require future administrative guidance or judicial interpretation.

Luca Pacioli – Andersen Global Perspective

Circular Note No. 13/2026 provides valuable clarification and significantly improves legal certainty regarding Tunisia's new Wealth Tax regime.

At the same time, it confirms the Tunisian tax administration's intention to adopt a comprehensive wealth-monitoring approach covering both domestic and international assets.

Business owners, high-net-worth individuals and international investors should therefore undertake a comprehensive wealth review to ensure compliance, document valuation methodologies and mitigate future tax risks.

Read more : Wealth Tax in Tunisia 2026: Scope & Exemptions - Luca Pacioli

Reach us : Tax Advisory & Transfer Pricing Tunisia - Luca Pacioli