The following expense types are either not deductible or only partially deductible for Ivory Coast tax purposes:

From 2017, failure to file the TP disclosure documentation (See Sec. 13.4.) or the filing of incomplete or incorrect disclosure entails the non-deductibility of all payments to related parties.
Interest charges paid to related parties are not deductible to the extent (a) the interest rate exceeds the rate of the Central Bank of West African States (BCEAO) plus 3 percentage points; or (b) the payers debt exceeds 100% of its paid-up capital; or (c) the interest is paid in remuneration of debt with a maturity of 5 years or more (See Sec 13.2.);
Royalties and service fees paid to non-resident related parties are deductible only if the payer proves that the payments are in remuneration of an effective transaction and are not excessive. Moreover, such payments are deductible only up to an amount not exceeding both 5% of the payer’s net turnover and 20% of its overhead. For these purposes, the net turnover or overhead base to take into account is that relating to the year during which the services were furnished. Equally, all payments subject to the limitation are aggregated in order to determine whether or not they exceed the turnover or overhead tests. The excess is not deductible.
From 2017, the double deduction ceiling of 5% of net turnover and 20% of overhead applies to payments to residents of countries and territories classified as low-tax or uncooperative jurisdictions regardless of whether or not the recipient is a related party. Moreover, in that case a third ceiling applies whereby the deduction may in no case exceed 50% of the amount of the payment. See Sec. 13.1. for definition of low-tax or uncooperative jurisdiction.
Donations are not deductible except if made to recognized public interest entities in the fields of education, health, culture or sport (deductible up to the lower of 2.5% of turnover or CFA 200 million per year); or in the form of financing infrastructure projects for local communities (deductible up to the lower of 3% of turnover or CFA 500 million).

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