bf-tax-optimization

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# Burkina Faso lawful tax comparisons v1.1

> **General reference only.** This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

## Who this applies to

Use only after collecting the legal form, activity, taxpayer regime, actual turnover and start date. Compare compliant alternatives on the same facts and period. No artificial turnover splitting, under-declaration or evasion is an option.

Use legal form and activity before comparing taxes: high turnover does not itself make a sole trader an IS company. Default IS forms and the signed IBICA election out for specified partnerships/GIE are in the corporate Guide. This workpaper is a conditional comparison, not a guaranteed saving. [CGI 2026 arts. 1, 28, 42–44](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf).

## Rates, bands and thresholds

| Item and conditions | Source |
|---|---|
| RNI applies from XOF 50m annual turnover excluding tax; start-year threshold is time-apportioned. Moving down requires three consecutive years below the threshold. | [CGI 2026 art. 527](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf) |
| RSI covers XOF 15m to below 50m annual turnover excluding tax, plus persons excluded from CME who are not RNI. Start-year thresholds are apportioned. Exceeding the threshold invalidates RSI during the year and must be notified within 30 days; downward CME eligibility requires three consecutive years below its limit. | [CGI 2026 art. 529](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf) |
| CME generally covers independent activities below XOF 15m: natural persons below 5m use forfait; natural persons from 5m to below 15m and legal persons below 15m use declarative CME. CSE taxpayers and liberal professions, regardless of form, are excluded. | [CGI 2026 arts. 533–534](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf) |
| IBICA CGA membership reduces profit tax 30%. Its minimum has a separate 50% membership reduction; apply both to their own amounts and still compare the minimum. New IBICA undertakings have first-operating-period MFP exemption. | [CGI 2026 arts. 14, 24–25, 27](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf) |
| RSI businesses have two accounting periods of patente exemption from effective start established by the tax administration. RSI CGA members receive 30% profit-tax, 50% MFP and 20% TPA reductions under art. 196; do not extend its profit-tax reduction to all RNI companies. | [CGI 2026 art. 196](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf) |
| CME members of approved CGAs receive a 25% contribution reduction, not the IBICA 30% profit-tax reduction. | [CGI 2026 art. 197](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf) |
| Article 228 grants CGA employers a 20% TPA base abatement and article 229 sets 3% of the applicable base. Article 196 separately states a 20% TPA reduction for RSI CGA members. The interaction, including cumulation or exclusion, is unresolved; an article-228-only illustration is not a final payable amount for article-196 eligibility. | [CGI 2026 arts. 196(2), 228–229](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf) |
| Company CGA membership separately halves MFP under art. 89; newly created companies have first-operating-period MFP exemption under art. 90. These do not create a general holiday from ordinary profit IS. | [CGI 2026 arts. 89–90](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf) |

## The base

CME replaces IBICA, IS, MFP, TPA and patente for covered professional activities. Other taxes remain under ordinary law; CME is not a universal exemption. Use the business Guide for full tariff zones/classes, ambulant branches and calculations. [CGI 2026 art. 532](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf).

Ordinary taxable RNI business is within VAT scope, with State/public-body industrial/commercial activity also covered. Special VAT option exists for specified agricultural/forestry/fishing operators regardless of turnover and RNI road transport only for transport. It is irrevocable from the first day of election month. Do not turn the old only-RNI slogan into a prohibition on every special option or import obligation. [CGI 2026 arts. 300–301](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf).

Deductible expenses belong to the period, serve direct business interest/normal management, are real and sufficiently documented and booked as expenses, reduce net assets and generate non-exempt income. The specific arts. 54–84 conditions apply as well. A payment or invoice alone does not prove deductibility. [CGI 2026 art. 53](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf).

Employee remuneration needs actual work. For managing associates of capital companies or their spouses, excessive or fictitious remuneration makes the whole payment a deemed distribution. No artificial salary deduction is offered here. [CGI 2026 arts. 54, 56](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf).

For IBICA mixed private/business costs, allocate the actual business portion; only where precise allocation cannot be established does art. 11 retain two-thirds. Do not make the fallback an elective higher deduction when actual allocation is known. [CGI 2026 art. 11](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf).

The company comparison uses 27.5% IS on profit rounded down to XOF 1,000 and MFP at 0.5% of turnover rounded down to XOF 100,000, with RSI floor XOF 300,000. It assumes no exclusive-activity exception, first-period exemption or other credits. The larger ordinary tax/minimum controls before valid credits; full RNI and special branches remain in the corporate Guide. [CGI 2026 arts. 87–89](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf).

## Deadlines and filing

CME taxpayers can elect RSI by letter to the tax service before 1 February. Effective 1 January in the election year, irrevocable three years, then withdraw in January. This is not automatic acceptance of every VAT deduction. [CGI 2026 art. 535](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf).

An eligible RSI taxpayer can apply to the DGI for RNI before 1 February. Acceptance is notified within 30 clear days of receipt; silence means acceptance. Must be current on declarations/payments, have normal SYSCOHADA accounts and standardised invoicing, and sign a timely VAT declaration/payment undertaking. [CGI 2026 art. 530(1)–(2)](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf).

RNI option takes effect 1 January of approval year, irrevocable three years; after that taxpayer withdrawal is by January letter. Administration can revoke at any time for art. 561ff non-compliance. Both RNI and RSI require normal SYSCOHADA accounts. [CGI 2026 arts. 528, 530(3)–531](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf).

## Penalties and interest

Comparison is not a filing extension or sanction waiver. Each routed Guide retains the relevant late filing/payment rules; no generic penalty amount is offered here and no assumed aggregation of different penalties is allowed. [CGI 2026 arts. 754–758, 776–778](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf).

## Cross-border points

No investment code approval, mining relief, duty holiday, treaty entitlement, foreign residence outcome or permanent-establishment attribution is established here. Route related-party and foreign-service transactions before accepting any expense or cash-flow projection.

A regime election does not remove controlled-pricing or non-resident withholding duties. Use the respective Guides before treating a related-party fee as deductible or a gross foreign invoice as net payment. Treaty relief and investment/mining approvals are not established by this workpaper. [CGI 2026 arts. 65–66, 98-1–98-2, 210–214](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf).

## Two worked examples that recompute

**RSI CGA relief does not erase the minimum.** Assume an established RSI company, effective CGA membership, adjusted profit XOF 400,000 and annual turnover XOF 20,000,000, with no other credits or exclusions. Ordinary IS is XOF 110,000; art. 196 reduces it to XOF 77,000. The XOF 300,000 RSI floor, halved for CGA, is XOF 150,000 and controls. The comparison company without membership owes XOF 300,000. This is statutory tax difference only: membership fees and other costs are not supplied or assumed. Rates and minimum conditions are owned by [corporate tax](bf-corporate-tax.md), CGI arts. 87–89 and 196.

```oa-check
name: RSI CGA profit relief and controlling minimum
inputs:
  profit: 400000
  turnover: 20000000
steps:
  ordinary_profit_tax: profit * 0.275
  member_profit_tax: ordinary_profit_tax * 0.70
  ordinary_minimum: max(floor(turnover / 100000) * 100000 * 0.005, 300000)
  member_minimum: ordinary_minimum * 0.50
  member_tax: max(member_profit_tax, member_minimum)
  nonmember_tax: max(ordinary_profit_tax, ordinary_minimum)
  tax_difference: nonmember_tax - member_tax
expected:
  member_profit_tax: 77000
  member_tax: 150000
  nonmember_tax: 300000
  tax_difference: 150000
```

**Article 228 base calculation, with the article 196 interaction unresolved.** Assume a liable CGA employer with XOF 1,000,000 remuneration/benefits in the article 228 base and no separate exemption. Applying the verified 20% base abatement gives XOF 800,000; article 229's 3% gives XOF 24,000 at this calculation stage. The same gross base at 3% before that abatement is XOF 30,000, a XOF 6,000 difference attributable to article 228 alone. Article 196 separately states an RSI CGA TPA reduction. Its interaction with article 228 is unresolved here, so this example supplies neither a final payable amount nor a conclusion for or against combining the provisions. Employee IUTS and CNSS are separate and not computed here.

```oa-check
name: Article 228 TPA base calculation before unresolved relief interaction
inputs:
  gross_base: 1000000
steps:
  article228_base: gross_base * 0.80
  article228_229_amount: article228_base * 0.03
  pre_abatement_amount: gross_base * 0.03
  article228_only_difference: pre_abatement_amount - article228_229_amount
expected:
  article228_base: 800000
  article228_229_amount: 24000
  pre_abatement_amount: 30000
  article228_only_difference: 6000
```

## Ask the client first

Obtain legal form and activity, start date and time-apportioned turnover, current and prior three years’ turnover/regime, election letters and dates, filing/payment compliance, accounting/invoicing systems, effective CGA membership evidence, profit reconciliation, VAT input eligibility and customer contracts, and actual membership/adviser costs. A tax reduction is not net savings until those costs are known.

## Sources

| Official source | Read on | What was actually read |
|---|---|---|
| [DGI, CGI 2026](https://dgi.bf/wp-content/uploads/2026/10/CGI-2026-v2.pdf) | 2026-11-01 | Selected articles 11, 14, 24–27, 53–56, 65–66, 87–90, 98-1–98-2, 196–197, 210–214, 228–229, 300–301, 527–540 and neighbouring conditions; actual 2026 text, including 2025 amendment annotations. Not the whole volume. |

The [figure/rule ledger](../../evidence/ledgers/burkina-faso-legacy-jobs-20261101/bf-tax-optimization.md) records each rule, original-language quote and read scope. The [predecessor map](../../evidence/ledgers/burkina-faso-legacy-jobs-20261101/old-topics.md) records every original topic, including retained gaps.

Not yet confirmed: CGA admission procedure, effective eligibility evidence, fees and service costs; filing/withdrawal form box IDs, authenticated eSINTAX workflows and proof of option receipt; controlling interaction between the article 196 RSI TPA reduction and article 228 base abatement, including any cumulation or exclusion; the article-228-only illustration does not establish final payable TPA; special VAT options/import and exemption interactions beyond the linked Guide; IBNC reduction/exemption branches not explicitly computed here; net commercial savings, investment/mining/sector approvals, reorganisation and treaty relief; any automatic best-regime claim; accountant attestation.

Written by OpenAccountants from the cited sources. Independent source review: conditional source corrections closed for this rewrite. Accountant attestation: none.

## Today's figures and who stands behind this skill

This file is an AI skill (tax rules your AI follows) from OpenAccountants, copied on 2026-11-01. Rates, thresholds and deadlines change. For the current version of this skill, its official sources and the named accountant (if any) who stands behind it, call `get_skill` with slug `bf-tax-optimization` on the OpenAccountants connector (https://www.openaccountants.com/connect), or read https://www.openaccountants.com/skills/bf-tax-optimization. If neither is available, confirm every figure against the official source pages cited above before relying on it.

From openaccountants/openaccountants, AGPL-3.0.

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