SCI in Ivory Coast: which tax regime for your property holding company?
Unfurnished letting or commercial activity: the tax regime of an Ivorian SCI changes completely. IRF and IPF rates, BIC, patente, exemptions, and ACD costs: what the Code Général des Impôts actually says.
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One legal form, two tax regimes
The Société Civile Immobilière (SCI), a civil (non-trading) property holding company, is used to structure the ownership of land and buildings. For the diaspora, it offers a formal framework for investing together with others, organising succession, and keeping personal assets separate from property assets.
The tax regime, on the other hand, does not follow from the legal form. It follows from the activity actually carried out. An SCI that limits itself to unfurnished letting and an SCI that builds in order to sell are not taxed in the same way. The rate changes, the tax base changes, and so do the accounting obligations.
SCI in unfurnished letting: the civil regime (pass-through)
When an SCI limits itself to letting unfurnished buildings, with no furniture and no ancillary services, it carries out a civil activity. This is the lighter of the two regimes, both in rates and in formalities.
How the tax works
A civil SCI is fiscally transparent: tax is assessed directly in the name of each partner, in proportion to their share in the company. The SCI itself pays no tax on profits.
Applicable rates
| Tax | Rate | Base |
|---|---|---|
| IRF (Impôt sur les Revenus Fonciers, property income tax) | 3 % | Rental value |
| IPF (Impôt sur le Patrimoine Foncier, property assets tax), let property | 9 % | Rental value |
| IPF, main residence | 0.5 % | Rental value |
| Patente (business licence tax) | Not applicable | Not relevant |
Source: Code Général des Impôts (General Tax Code), dgi.gouv.ci
A note on figures: Ivorian tax texts use the comma as decimal separator. The rates quoted here as 0.5 % and 0.2 % appear as 0,5 % and 0,2 % in the official documents.
Advantages
Bookkeeping stays light, with no commercial balance sheet required, and the patente is not payable. Tax follows the personal income tax scale, which is often more favourable than the rate applied to commercial profits. One last point, less about tax and just as useful day to day: partners remain free to allocate the shares between themselves, which leaves room to organise an arrival, a departure, or a gift.
Commercial SCI: the BIC regime
If the SCI carries out a commercial activity, it moves under the Bénéfices Industriels et Commerciaux (BIC, industrial and commercial profits) regime, which is appreciably heavier. The Ivorian Code Général des Impôts identifies three activities that push an SCI across that line.
Furnished letting comes first: supplying the furniture is enough to turn a civil activity into a commercial one. Then building in order to sell, in other words property development. And letting combined with services, such as security or cleaning.
Applicable rates
| Tax | Rate | Base |
|---|---|---|
| BIC | 25 % | Net profit |
| IRF | 4 % | Rental value |
| IPF, let property | 11 % | Rental value |
| IPF, business property | 13 % of market value | 2026 tax annex (annexe fiscale 2026; rate brought down from 15 % to 13 %) |
| Patente | Yes | Varies with turnover |
Consequences
The switch produces four effects. The SCI becomes liable to BIC, that is 25 % on net profit. It must keep full commercial accounts. It pays the patente contribution. And its IPF rates are increased.
Full comparison table
| Criterion | Civil SCI (unfurnished letting) | Commercial SCI |
|---|---|---|
| Typical activity | Letting unfurnished buildings | Furnished letting, building in order to sell |
| Tax on profits | IR (income tax, in the partners' names) | BIC (25 % in the SCI's name) |
| IRF rate | 3 % | 4 % |
| IPF rate (let property) | 9 % | 11 % |
| Patente | No | Yes |
| Bookkeeping | Simple | Commercial, mandatory |
| Overall tax cost | Lower | Higher |
Which exemptions apply
Several situations fall outside IPF, in whole or in part.
Associations and non-profit organisations (organismes à but non lucratif, OBNL) are exempt from IPF on buildings used for their stated purpose: places of worship, schools, hospitals. Diplomatic missions benefit from an exemption provided for by international conventions. Long leases (baux emphytéotiques) fall under a reduced rate, 0.2 % of market value (2026 tax annex). First-time buyers have a tax credit of 5 % on their first home, where the price is 40 million FCFA or less (roughly 61,000 EUR). Finally, newly acquired bare land is exempt from IPF for two years (2025 tax annex).
SCI and land: the points to check
Can an SCI hold an Arrêté de Concession Définitive (ACD, Definitive Concession Decree)?
Yes. An SCI can be the holder of an ACD and of a Titre Foncier (TF, Land Title) in Ivory Coast (Côte d'Ivoire). The fee, however, depends on the nature of the applicant: individual or legal entity.
Official timeframe: according to the texts of the Ivorian administration, 180 calendar days at the Ministère de la Construction, du Logement et de l'Urbanisme (MCLU, Ministry of Construction, Housing and Urban Planning) for an ACD on an approved subdivision (BÂTIR No. 004, 2022), not counting processing at the tax administration. In practice, the total time experienced is often longer, for a variety of reasons that cannot always be explained. Worth noting: the Titre Foncier is created by the Conservation de la Propriété Foncière et des Hypothèques (CPFH, Land Registry and Mortgages Office) during the ACD procedure (official step 3), not afterwards. The ACD published in the Livre Foncier (Land Register) is the published Land Title itself.
| Profile | ACD cost |
|---|---|
| Individual | 100,000 FCFA/lot + 1,000 FCFA/file + 50,000 FCFA |
| Company or SCI | 450,000 FCFA/lot + 1,000 FCFA/file |
The application is filed at the Guichet Unique du Foncier et de l'Habitat (GUFH, One-Stop Land and Housing Office), on 27 20 21 74 78.
Source: servicepublic.gouv.ci
The SCI and rural land
In the rural land domain, Law No. 98-750 reserves ownership to natural persons of Ivorian nationality. An SCI, being a legal entity, therefore cannot hold a rural Certificat Foncier (CF, Land Certificate). It can, on the other hand, enter into a lease on rural land.
Do not transpose one regime onto the other. Rural land (Law No. 98-750) and urban land (Ordinance No. 2013-481) rest on different ownership rules and different transfer procedures.
Source: afor.ci
Practical advice before setting up an SCI
- Draw the corporate purpose tightly. Staying with "acquisition, management and letting of unfurnished buildings" limits the chance of being reclassified as a commercial activity.
- Avoid furnished letting if you want to stay in the civil regime. A single batch of furniture is enough to tip the SCI into BIC.
- Have the structure reviewed by a tax specialist before incorporation. The choices made at the outset keep producing their effects for years.
- Give the articles of association proper attention at a notary. The allocation of shares, the transfer rules, and the split-ownership clause are negotiated once, not twice.
- Declare your property income to the Direction Générale des Impôts (DGI, General Tax Directorate), financial year after financial year, to avoid penalties.
Sources:
- Code Général des Impôts, dgi.gouv.ci
- 2025 tax annex: IPF exemption on bare land
- 2026 tax annex: IPF cap, business rates, tax credit
- servicepublic.gouv.ci: ACD costs
- afor.ci: rural land, Law No. 98-750
- Ordinance No. 2013-481: urban land domain
Further reading:
- Property assets tax: an owners' guide
- 2026 tax annex: the five major changes
- Bare land in an urban area: taxation
- Investing from the diaspora
?Frequently asked questions
Can an SCI be set up from the diaspora?+
Yes. Incorporation goes through a notarised power of attorney, with no obligation to be physically present in Ivory Coast. The notary drafts the articles of association, then the SCI is entered in the Registre du Commerce et du Crédit Mobilier (RCCM, Trade and Personal Property Credit Register).
How much does it cost to set up an SCI?+
Budget between 300,000 and 800,000 FCFA (roughly 460 to 1,220 EUR): notary fees, RCCM registration, and sundry costs. The law sets no minimum share capital, so it can be symbolic.
Does an SCI protect you in the event of a dispute?+
The SCI keeps the property assets separate from the partners' personal assets. If a dispute arises over an asset held by the SCI, your personal assets are not directly exposed. That separation only holds, however, if the company is properly incorporated and genuinely run as one: meetings held, accounts kept up to date, decisions recorded in writing.
What is the difference between an SCI and a property SARL?+
The SCI is a civil company: civil purpose, pass-through tax regime. The SARL is a commercial company: commercial accounts, BIC, patente. For holding assets without operating them, the SCI fits the purpose better.
Does an SCI pay the property assets tax?+
IPF is due on the buildings held by the SCI. The rate depends on the activity: 9 % in unfurnished letting (civil regime), 11 % in commercial activity. The cap at +25 % provided for by the 2026 tax annex applies.
