A non-resident entity operating in Guinea is subject to tax on income earned from its business activities in Guinea. Such income is subject to tax at the same rate as applicable to resident companies.
The after-tax profit of the branch is deemed to have been remitted to the foreign head office and is subject to a branch profit remittance tax at 10%. The non-resident enterprise may request a refund of excess paid branch profit tax if it can prove that actual remittances to the head office are lower than the after-tax profits. For these purposes, actual remittances comprise not only actually remitted after-tax profits but also all other deemed distributions such as disallowed deductions (e.g. head office overhead in excess of 10% of turnover).
Guinea-sourced income earned by non-residents not having a PE in Guinea, is subject to withholding tax in the country.