A group taxation regime is available upon request and subject to meeting various conditions. Once granted, the regime applies for a minimum period of five years, which is renewable for successive five-year periods by tacit approval unless the group heads opts for the termination of the regime at the end of a 5-year period. The group taxation regime is elective and open to all resident companies provided:

The group head holds directly or indirectly at least 75% in the capital of all entities to be included in the consolidation perimeter (and the participation does not fall below 75% during the entire application period of the regime);
The group head and all entities included in the consolidation perimeter are Tunisian residents, are subject to corporate income tax and follow the same fiscal year; and
The group head commits to become listed on the stock exchange by the end of the year following the one during which the consolidation regime first applied. A one-year grace period may be granted by the Minister of Finance subject to the filing of a motivated report by the Financial Markets Authority.

Under the regime, the profit and losses of all group members are pooled, and the group head is liable to tax on behalf of all group members. Nevertheless, the individual group members remain jointly liable for the payment of tax proportionally to their respective corporate tax liabilities had they not been members of a consolidated group.

Losses generated by a group company prior to the consolidation are to be carried forward.

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