Cd Corporate Income Tax

---
name: cd-corporate-income-tax
description: "Prepare an ordinary company income-tax workpaper for DR Congo for income earned in 2026 under the IS reform. Use this Guide to screen corporate form, territory and exemptions; reconcile accounting profit with supported tax adjustments; compare profit tax with the turnover minimum; and schedule provisional payments and the annual declaration. It covers selected expense restrictions, loss conditions, financial-statement attachments and the separate assembly-minutes deadline. The output is a calculation and filing-preparation file, not evidence of a submitted return. Mining, small-business classification, transitional losses, complete capital allowances, treaty relief and authenticated electronic filing require separate source work. Trigger phrases include Congo company tax, IS, minimum tax, provisional instalments and corporate return."
license: "AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)"
metadata:
  source: openaccountants
  openaccountants_url: "https://www.openaccountants.com/skills/cd-corporate-income-tax"
  jurisdiction: "CD"
  tax_year: "2026"
  last_updated: "2026-11-01"
---

# DR Congo corporate income tax: ordinary IS workpaper v1.1

## Who this applies to

**RESEARCH HOLD.** Finance Law 25/060 article 16 carries selected provisions of Finance Law 24/011 into 2026. The original enacted 24/011 provisions have not been fully retrieved and reconciled in this expansion. Use the cited rules below only as a conditional research workpaper until that chain and the stated scope conditions are established. Do not report final 2026 liability or filing readiness from this draft. [2026 Finance Law,art.16](https://www.budget.gouv.cd/wp-content/uploads/budget2026/lf_2026_recettes.pdf).

Use this draft for an ordinary, non-mining company whose 2026 income is established as subject to Impôt sur les Sociétés (IS). It prepares a tax reconciliation, minimum-tax comparison and filing checklist.

SA, SARL and SAS entities, including single-member entities, are taxable by form. Article 3 also lists activity-based taxpayers. SNC, SCS and sociétés en participation enter by an option that article 4 makes irrevocable; it excludes partnerships resulting from an earlier transformation of a share company and requires the assembly minutes to be notified by the manager to the competent tax service within the first three months of the fiscal year. Do not treat every partnership as automatically subject to IS. [Law 23/053, arts.3–4](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf).

Screen the exemptions in articles 5–6 before using the computation: public bodies funded solely by budget subsidies; qualifying civil agricultural/livestock/fishing cooperatives; legally constituted nonprofit associations and specified nonprofit events; public-benefit bodies/NGOs under regulatory conditions; exclusively technical, professional or special private education; GIE profits distributed to individual members; and qualifying foreign transport profits subject to reciprocity. These are conditional categories, not a blanket exemption for a company with an exempt shareholder. Establish all category conditions separately. [Law 23/053, arts.5–6](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf).

Article 153 provides commencement after twenty-four months from 31 December of the promulgation year; the Ministry identifies the reform's entry into force as 1 January 2026. This job concerns income earned in 2026, not a declaration of 2025 IBP income merely filed during 2026. [Law 23/053, art.153](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf); [Ministry reform page](https://finances.gouv.cd/reformes/reforme-fiscalite-directe-is-irpp).

## Rates, bands and thresholds

| Item | Amount and conditions | Tax year | Official source |
|---|---|---|---|
| Ordinary IS | 30% of net taxable profit for a company within this job, after supported adjustments and available losses | 2026 | [Law 23/053 art.56](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf) |
| Turnover minimum | 1% of declared turnover if results are a loss or the profit-based tax is below this amount; compare the two liabilities, do not add them together | 2026 | [Law 23/053 art.57](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf) |
| Advertising gifts and purpose-made advertising objects | Deduct invoiced qualifying cost only within 2 per thousand, equivalent to 0.2%, of turnover excluding tax, subject also to general deduction conditions | 2026 | [Law 23/053 arts.20 and 49(1)](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf) |
| Representation expenses | Invoiced qualifying expenses deductible within 60% of their amount, subject also to general deduction conditions | 2026 | [Law 23/053 arts.20 and 49(2)](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf) |
| Communications | Invoiced qualifying expenses deductible within 50%; internet costs deductible at 100% only for exclusively professional use, subject also to general deduction conditions | 2026 | [Law 23/053 arts.20 and 49(7)](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf) |
| Loss carry-forward | A qualifying loss is deductible against the next period, with an unused balance carried no later than the third period following the loss year; conditions and exclusions below apply | 2026 regime | [Law 23/053 arts.51–52](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf) |
| Provisional payments | First two each 30%, third 20%, of prior declared tax plus administrative supplements, or tax assessed by default if no declaration, whether disputed or not | 2026 income | [Finance Law 25/060 art.31 replacing Procedures Law 004/2003 art.57 bis](https://www.budget.gouv.cd/wp-content/uploads/budget2026/lf_2026_recettes.pdf) |

## The base

Article 7 covers profits of enterprises operated or operations carried out in DR Congo and profits allocated to it by a double-tax convention. Subject to conventions, it includes resident companies with their registered office or effective management there and nonresidents with a permanent establishment. This is not a worldwide-income rule for every company. Resolve an uncertain residence, source, permanent establishment or treaty allocation before calculating. Article 8's complete establishment analysis is outside this workpaper. [Law 23/053 arts.7–8](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf).

Start from accounting income less expenses, subject to fiscal adjustments. The net-asset reconciliation removes additional capital contributions and adds shareholder withdrawals; asset disposals are included. Stocks use cost, including prepaid goods not yet received; work in progress uses cost excluding general and financing expenses. [Law 23/053 arts.9–10](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf).

For each expense, article 20 requires direct business interest or normal management, an actual charge supported by persuasive evidence, a reduction of net assets and recognition in the period incurred. For amounts subject to a levy or withholding, retain proof of the corresponding declaration and payment. General conditions do not override a specific cap or disallowance. Apply the table's advertising, representation and communications limits only after those conditions are met. [Law 23/053 arts.20 and 49](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf).

Article 50 disallows personal costs; income taxes and other taxes that are not operating expenses; the exceptional expatriate-employer levy; fines, confiscations and penalties under tax, customs, social and other law together with related fees/costs; specified pleasure/sporting expenses; and foreign head-office administration/general costs and other foreign costs of a nonresident allocated to its permanent establishment. Provisions are generally disallowed, with express exceptions for mining-deposit reconstitution and specified compulsory certified credit/microfinance and insurance/reinsurance provisions. Rental-asset costs including depreciation have a statutory restriction with an exception for a credit-lessor duly approved by the Central Bank. Do not resolve an ordinary property company's deduction claim without reconciling this restriction with article 49(3). [Law 23/053 arts.49(3) and 50](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf).

Keep a loss schedule by originating year, declared fiscal result and use. Article 51 excludes foreign-business losses and a loss for a year not declared after a formal demand. Regularly recorded depreciation deferred in a loss period is treated as an ordinary deficit. Article 52 denies inherited losses to a new operator buying the loss business and after a complete activity change or a transformation of composition/activity that leaves it no longer the same business. Determine profit/loss before previous losses, and record any deferred depreciation distinctly in the depreciation table. Whether pre-reform IBP losses transfer into IS is not established here. [Law 23/053 arts.51–52](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf).

Apply `max(30% × positive net taxable profit, 1% × declared turnover)` only after the ordinary scope and bases are established. A loss does not remove the turnover minimum. Article 150 sets statutory rounding: a decimal goes to the franc above if the first decimal is 5 or more, otherwise to the franc below; a remainder of CDF 50 or more then goes to the hundred above, and a remainder below CDF 50 to the hundred below. [Law 23/053 arts.56–57 and 150](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf).

## Deadlines and filing

| Obligation | Statutory point and conditions | Official source |
|---|---|---|
| Accounts and annual tax period | Accounts ordinarily close on 31 December and the period is the calendar year; cessation and first-year rules below apply | [Law 23/053 art.12](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf) |
| Annual IS declaration | No later than 30 April of the following year; for ordinary 2026 income this gives 30 April 2027, before any separately established extension | [Finance Law 25/060 art.18 replacing Procedures Law art.12](https://www.budget.gouv.cd/wp-content/uploads/budget2026/lf_2026_recettes.pdf) |
| Three provisional payments | No later than 25 July, 25 September and 25 November of the income year, using the administration's provisional-payment slip | [Finance Law 25/060 art.31, Procedures Law art.57 bis](https://www.budget.gouv.cd/wp-content/uploads/budget2026/lf_2026_recettes.pdf) |
| Final balance | Deduct the three payments from the year's liability; pay any balance when the annual declaration is submitted | [Finance Law 25/060 art.31, Procedures Law art.57 bis](https://www.budget.gouv.cd/wp-content/uploads/budget2026/lf_2026_recettes.pdf) |
| Assembly minutes | Deposit minutes within ten days of the ordinary assembly approving financial statements certified by the statutory auditors | [Finance Law 25/060 art.19 inserting Procedures Law art.13 bis](https://www.budget.gouv.cd/wp-content/uploads/budget2026/lf_2026_recettes.pdf) |

A first accounting period starting in the first half can be shorter than twelve months. A business created after 30 June can close its first accounts on 31 December of the next year, but the creation-year profit is still taxed using intermediate accounts at that first 31 December and deducted from the later first closed-period result. Do not defer all creation-year tax because the first statutory accounts cover a longer period. Dissolution, merger/scission and liquidation have the separate immediate/special-assessment rules of article 13 and need their own workpaper. [Law 23/053 arts.12–13](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf).

Prepare the file in this order:

1. Confirm the company, taxpayer number, fiscal period and ordinary IS status; identify any exemption, treaty, special sector or reform transition before using the rates.
2. Reconcile taxable profit, declared turnover, available losses and all prior payments to supporting records. Record unresolved deductions separately instead of assuming acceptance.
3. Obtain the current declaration and provisional-payment slip from the tax administration. DGI's public instructions require a completed, dated and signed declaration by the taxpayer or representative, with the bank's payment attestation. Its public service link points to [i-Impôts](https://i-impots.dgirdc.cd/). These are public entry points, not proof of an authenticated filing path. [DGI IS instructions](https://dgi.gouv.cd/impot-sur-les-societes/).
4. For normal accounting-system entities attach the balance sheet, income statement, cash-flow statement, statement of equity changes and notes, with other useful supporting documents; obtain the adviser/accountant countersignature and the summary of actual sales to traders/manufacturers. Entities under special accounting rules instead supply the applicable summary statements. [Procedures Law art.13 as replaced by Law 23/052 art.1, PDF4–5](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf).
5. Calendar the provisional payments, annual declaration/balance and separate assembly-minutes deposit. Reconcile each actual bank payment and administrative acknowledgement to the workpaper. Do not state that the declaration was submitted or accepted from a prepared file or a bank debit alone.
6. Stop before electronic submission: the current form number, field/box mapping, authentication, payment-reference generation and acceptance/receipt sequence have not been observed. Obtain that workflow and preserve its receipt before reporting filing completion. An overpayment in the calculation is not an automatic refund or permission to offset another tax.

Ordinary IS taxpayers must issue a normalised invoice or qualifying equivalent for each transaction, subject to the law's small-enterprise reservation; electronic equivalence depends on the prescribed conditions. The detailed invoice specification, rollout rules and technical validation are separate work, not established by this computation. [Finance Law 25/060 art.24 replacing Procedures Law art.23](https://www.budget.gouv.cd/wp-content/uploads/budget2026/lf_2026_recettes.pdf).

## Penalties and interest

Law 23/053 article 151 applies the amended Procedures Law's declaration, control, collection, sanction and appeal rules to IS. This draft does not supply a complete current penalty/interest calculation. Finance Law 25/060 article 23 permits a good-faith spontaneous correction of a timely return without prejudice to tax control, with late interest claimed by assessment notice; it does not exempt a late original return or establish a zero-interest correction. Obtain the actual current notice, applicable rate and procedure before costing a correction. [Law 23/053 art.151](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf); [Finance Law 25/060 art.23 inserting Procedures Law art.22 quater](https://www.budget.gouv.cd/wp-content/uploads/budget2026/lf_2026_recettes.pdf).

## Cross-border points

Use the [transfer-pricing Guide](cd-transfer-pricing.md) for connected-party pricing, special-destination and documentation screens, and the [nonresident-payment Guide](cd-cross-border.md) for separate payment classification and withholding. Neither a payment withholding nor a pricing adjustment automatically proves deductibility. Resolve the source-law deduction tests for related nonresident services, privileged regimes and noncooperative destinations before including these costs; this computation does not approve a treaty rate, PE attribution, foreign credit or sector concession. [Law 23/053 arts.46–48 and 53](https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf).

## Two worked examples that recompute

Both examples assume that the cited text governs after reconciliation of the carried-law chain, established ordinary IS scope for 2026, no sector or treaty adjustment and valid turnover and otherwise supported costs. The prior-tax base is an assumed independently established input, not a claim about the reform treatment of a particular taxpayer's 2025 assessment.

### 1. Expense reconciliation: profit-based tax is larger

Assume CDF1 billion turnover excluding tax and CDF80 million accounting profit after deducting CDF5 million invoiced representation, CDF2 million invoiced non-internet communications and CDF4 million qualifying advertising gifts. General expense conditions are met. Allowed costs are respectively CDF3 million, CDF1 million and CDF2 million; add back CDF5 million in total. Taxable profit is CDF85 million. Profit tax is CDF25.5 million, exceeding the CDF10 million minimum. With an independently established prior-tax base of CDF20 million, provisional payments are CDF6 million, CDF6 million and CDF4 million; the balance is CDF9.5 million.

```oa-check
name: Ordinary IS with supported capped expenses
inputs:
  turnover: 1000000000
  accounting_profit: 80000000
  representation: 5000000
  communications: 2000000
  advertising_gifts: 4000000
  prior_tax_base: 20000000
steps:
  representation_addback: representation - representation * 0.60
  communications_addback: communications - communications * 0.50
  gifts_addback: advertising_gifts - min(advertising_gifts, turnover * 0.002)
  taxable_profit: accounting_profit + representation_addback + communications_addback + gifts_addback
  profit_tax: max(taxable_profit, 0) * 0.30
  minimum_tax: turnover * 0.01
  liability: max(profit_tax, minimum_tax)
  first_payment: prior_tax_base * 0.30
  second_payment: prior_tax_base * 0.30
  third_payment: prior_tax_base * 0.20
  balance: liability - first_payment - second_payment - third_payment
expected:
  taxable_profit: 85000000
  profit_tax: 25500000
  minimum_tax: 10000000
  liability: 25500000
  balance: 9500000
```

### 2. Decision: low profit does not remove the minimum

Assume the same turnover but independently established final taxable profit of CDF20 million. Profit tax alone would be CDF6 million; the statutory minimum is CDF10 million, so CDF10 million is the liability before payments. If actual supported provisional payments total CDF16 million, the reconciliation shows CDF6 million in excess. This example decides between profit tax and minimum tax, not whether to apply for a refund: no refund entitlement or offset procedure is established here.

```oa-check
name: Minimum tax wins and excess payments stay separate
inputs:
  turnover: 1000000000
  taxable_profit: 20000000
  actual_provisional_payments: 16000000
steps:
  profit_tax: max(taxable_profit, 0) * 0.30
  minimum_tax: turnover * 0.01
  liability: max(profit_tax, minimum_tax)
  balance_to_pay: max(liability - actual_provisional_payments, 0)
  excess_payment: max(actual_provisional_payments - liability, 0)
expected:
  profit_tax: 6000000
  minimum_tax: 10000000
  liability: 10000000
  balance_to_pay: 0
  excess_payment: 6000000
```

## Ask the client first

- What legal form, IS election, business activity and exemption/special-sector status apply, and where are the registered office, effective management and operations?
- Which income year is being computed, when was the business created, and is there a cessation, reorganisation or pre-reform loss?
- What do the accounts, declared turnover and supporting invoices show, including capital contributions, withdrawals and capped or specifically restricted expenses?
- What loss declarations, formal demands, activity/ownership changes and depreciation schedules support each proposed loss use?
- What prior declared/default tax, supplements, disputes and actual provisional-payment evidence establish the payment reconciliation?
- Which tax office/current form, authenticated filing route, bank attestation and assembly approval date apply, and what unresolved cross-border issue prevents finalisation?

## Sources

| Source | Official URL | Read on and actual scope |
|---|---|---|
| Laws 23/052 and 23/053 of 30 November 2023, official combined gazette copy | https://dgi.gouv.cd/wp-content/uploads/2025/09/loi-is-et-Irpp.pdf | 2026-11-01: this expansion read procedure art.13 PDF4–5; IS arts.3–13 PDF12–15, art.20 PDF17, arts.46–57 PDF23–26 and final arts.150–153 PDF44. Cited scope checked visually against the scanned pages; detailed capital-allowance rules not reconstructed. |
| Finance Law 25/060 of 29 December 2025, 2026 revenue volume | https://www.budget.gouv.cd/wp-content/uploads/budget2026/lf_2026_recettes.pdf | 2026-11-01: expansion read articles 16–31 in relevant OCR, with articles 18–19 PDF17, 23–24 PDF19 and 31 PDF27 visually checked. Other source portions retain their separate prior read receipts. |
| Rectifying Finance Law 26/032 of 7 August 2026 | https://www.budget.gouv.cd/wp-content/uploads/budget2026/lfr_2026/lfr_2026_recettes.pdf | 2026-11-01: tax/commencement portions screened in actual captured OCR for changes to this job, including arts 14–19 and 49–51. Passive-income changes belong to the separate payment Guide; no claim that every annex or later instrument has been checked. |
| Rectifying Finance Law 25/044 of 28 June 2025, carried article 9 | https://www.budget.gouv.cd/wp-content/uploads/budget2025/budget2025_rect/lf_2025_recettes.pdf | 2026-11-01: actual PDF12–13 read,PDF12 visually checked. The carried article 9 concerns mediation/re-examination procedures; it does not supply the missing original 24/011 fiscal provisions. No complete 2025 law reconciliation claimed. |
| Ministry, IS/IRPP direct-tax reform | https://finances.gouv.cd/reformes/reforme-fiscalite-directe-is-irpp | 2026-11-01: reform commencement field, 1 January 2026, actually opened in web reader. |
| DGI, IS public declaration instructions | https://dgi.gouv.cd/impot-sur-les-societes/ | 2026-11-01: taxpayer, deadline, form/signature/bank-attestation instructions and observed public service links; no authenticated submission read. |

Not yet confirmed: full enacted 24/011 carried-measure reconciliation under 25/060 art.16; complete current penalty and interest rates/procedures; actual form numbers, field mappings, portal access, payment-reference and receipt workflow; first-year provisional-payment and 2025-IBP-to-2026-IS transition details; pre-reform loss carry-forward; complete depreciation, allowances, interest/thin-capitalisation and unrealised-gain/revaluation rules; property-company article 49(3)/50(4) interaction, provincial Kinshasa rental tax and tenant withholding; mining corporate rate/concessions and mining dividend relief; whether any historical small-company turnover thresholds or goods/service percentages apply to a particular legal entity under the current reform, and the micro-business ministerial lump sum; resident dividend/interest/royalty withholding, treaty and sector relief; complete PE/residence/source/foreign-credit/exit analysis; actual nonresident technical/passive-service boundaries. Former 2025 draft figures from PwC Tax Summaries, kept for reference and not current law: small company with turnover of CDF 25m to 300m, 1% of turnover on goods and 2% on services; micro company below CDF 25m, ministerial lump sum; Kinshasa rental tax 12% with 10% withheld by the tenant; mining 30%; dividends 20%, or 10% in mining; nonresident interest 0 to 20%; royalties 20% on the net amount after a 30% deduction; nonresident services 14%. every old topic is retained in the destination map or this explicit gap list. Country coverage remains partial.

## 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 `cd-corporate-income-tax` on the OpenAccountants connector (https://www.openaccountants.com/connect), or read https://www.openaccountants.com/skills/cd-corporate-income-tax. If neither is available, confirm every figure against the official source pages cited above before relying on it.