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4.3. Branch Profit (Deemed Remittance) Tax

Net profits after corporate tax realized in Guinea by the branch of a foreign enterprise, are deemed to be remitted to the foreign head office in respect of each fiscal year and subject to withholding tax at 10%. The taxpayer may request the reduction of the tax base in the event actual remittances to the head office are lower than the after-tax profits. For the purpose of establishing this proof, actual remittances are defined to include not only the remittance of after-tax profits but also any other direct and indirect transfers such as disallowed deductions (e.g. head office expenses in excess of 10% of the branch turnover).