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5.2. Treatment of Foreign Profits / Losses

Under the prevailing territorial principle, only income attributable to a business carried out in Ivory Coast is taxable therein. Business income attributable to an establishment abroad (see definition under Secs. 4.1. and 4.2.) is not taxable in Ivory Coast, but foreign passive income is. In application of the same principle, losses from a foreign business establishment may not be set off against positive taxable income (but there is a temporary deduction, followed by a recapture, for certain initial expenses connected to the opening of a foreign business establishment, see Sec. 4.2.).