Ml Corporate Income Tax

---
name: ml-corporate-income-tax
description: "Mali corporate income tax research draft for 2026, using an explicitly older DGI statutory baseline whose later amendment chain remains unproved. Use it to prepare a conditional company profit-tax workpaper, distinguish companies from transparent businesses, reconcile accounting profit and deductions, compare ordinary profit tax with the turnover minimum, identify instalments and reconstruct the source filing timetable. It also preserves the former Guide's dividend, interest and non-resident-payment topics with instrument and base distinctions. Mining conventions, treaty relief, current forms and portal boxes need separate verification. Two executable cases test the source arithmetic only. No accountant has attested to this version and no operative 2026 coverage is claimed."
license: "AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)"
metadata:
  source: openaccountants
  openaccountants_url: "https://www.openaccountants.com/skills/ml-corporate-income-tax"
  jurisdiction: "ML"
  tax_year: "2026"
  last_updated: "2026-11-01"
---

# Mali corporate income tax source-reference draft v0.1

> **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.

**2026 research draft; operative 2026 law is unproved.** This is a conditional source-reference workpaper, not an approved current-law computation. The DGI online consolidation contains amendments labelled through 2017 in the provisions used here. No complete later amendment chain or enacted 2026 fiscal Annex U has been reconciled. Read every rule below as a statement of that identified source baseline, not proof it applies unchanged in 2025 or 2026. Do not calculate a client's 2026 liability or instruct a 2026 filing from this draft. The current-year metadata identifies the research job; it is not evidence of currentness or a technical retrieval/publication safeguard.

## Who this applies to

The older CGI establishes IS in the name of a société anonyme, société à responsabilité limitée or société en commandite par actions. A société en commandite simple can expressly opt into that treatment. Individuals and partners are dealt with separately; legal form and elections must be established before computing a company liability. The ordinary business chapter includes commercial, industrial, craft and professional profits. [CGI arts. 43–46, 82–84](https://www.dgi.gouv.ml/CGI/).

This workpaper concerns an ordinary real-regime company with Mali business profits. The territorial rule is subject to ratified double-tax conventions. Mining and petroleum businesses follow their special legislation; no universal mining rate is established here. Stabilisation clauses, investment approvals, exemptions and reorganisations are outside the ordinary computation. [CGI arts. 44–47, 45, 87–93](https://www.dgi.gouv.ml/CGI/).

## Rates, bands and thresholds

| Item | Identified older DGI baseline, not approved 2026 law | Official source |
|---|---|---|
| Ordinary IS | 30%; taxable base rounded down to XOF 1,000 | [CGI art. 85, Loi 11-078](https://www.dgi.gouv.ml/CGI/) |
| Real-regime turnover minimum | 1% of tax-exclusive turnover rounded down to XOF 1,000, including operating and accessory products for IS; applies even to a loss | [CGI art. 86, amendment labels through LF 2015](https://www.dgi.gouv.ml/CGI/) |
| Additional minimum tests | When turnover is at least the real-regime eligibility threshold, art. 86 final paragraph imposes a further floor by reference to the IBIC portion of maximum contributions; property-rental companies have the separate IRF comparison in art. 86-A. Neither is silently set to zero | [CGI arts. 86–86-A](https://www.dgi.gouv.ml/CGI/) |
| Real regime | At least XOF 50 million annual tax-exclusive turnover, plus named compulsory professions/approved enterprises and valid elections | [CGI arts. 70–79](https://www.dgi.gouv.ml/CGI/) |
| Real-simplified mode | XOF 50 million through XOF 250 million annual turnover excluding VAT, with commencement/cessation proration and option exceptions; others go to real-normal | [CGI arts. 76–79](https://www.dgi.gouv.ml/CGI/) |
| Ordinary loss carryforward | Through the third exercise following the loss exercise; keep tax depreciation deferred in loss years separately | [CGI arts. 51(4), 51(10), 60](https://www.dgi.gouv.ml/CGI/) |
| Real-normal instalments | Three; each one quarter of the last IBIC/IS assessment | [LPF arts. 275, 278, 280](https://www.dgi.gouv.ml/CGI/) |
| Real-simplified instalments | Total 0.60% of previous-year turnover, paid in three equal parts; petrol stations sourcing exclusively on the local market use the distinct 0.20% coefficient | [LPF arts. 276–277](https://www.dgi.gouv.ml/CGI/) |

## The base

1. Reconcile the accounting period. The source normally aligns it with the calendar year, with special first-period rules. Start from all business operations, including asset disposals, and bridge the accounting result to taxable profit. [CGI arts. 48–50](https://www.dgi.gouv.ml/CGI/).
2. Deduct only effective, sufficiently supported expenses incurred in the business interest or normal management, reducing net assets, recorded in the correct period and contributing to non-exempt profit. Remuneration must represent actual work and not be excessive. IBIC and the minimum profit tax are excluded deductions. Accounting recognition alone does not establish tax deductibility. [CGI arts. 49, 51(1)–(3)](https://www.dgi.gouv.ml/CGI/).
3. Reconcile depreciation, provisions, eligible losses and their expiry year. The source permits linear depreciation actually booked within accepted usage and separately identified depreciation deferred in loss years. Do not invent an asset rate, passenger-car cap, current interest limit or exemption. The general loss rule above does not prove those specific deductions. [CGI arts. 51, 60–61](https://www.dgi.gouv.ml/CGI/).
4. Round the positive taxable profit down to the statutory unit and apply the profit rate. Separately round tax-exclusive operating and accessory turnover, calculate the turnover minimum and determine the additional art.86 final-paragraph floor only if turnover meets its real-regime-threshold condition. Compare those amounts; a loss eliminates ordinary positive-profit tax, not the minimum. Property-rental companies need their separate comparison. If the additional floor cannot be established, stop before finalising liability. [CGI arts. 85–86-A](https://www.dgi.gouv.ml/CGI/).
5. Reconcile allowable instalments actually paid against the annual assessment, excluding their penalties. A working paper records period, legal form, regime, accounting-to-tax bridge, losses by year, both minimum checks and payment evidence; these are not official form boxes. [LPF arts. 60, 281–285](https://www.dgi.gouv.ml/CGI/). Enacted Loi 2025-056 article 46 refers to fiscal Annex U, which is absent from the gazette obtained in the earlier batch. No rule is inferred from that missing annex. The separately reviewed [historical CSS Guide](ml-solidarity-contribution.md) retains its own 2025 scope and mandatory 2026 hold.

## Deadlines and filing

In this source baseline, real-regime profit or loss is declared within the first four months after year end, so an ordinary calendar-year closing gives an end-of-April deadline, not the old Guide's general March deadline. Insurance companies have a separate 31 May deadline. The administration's prescribed form is required. [LPF art. 57](https://www.dgi.gouv.ml/CGI/).

The declaration includes detailed general expenses and the SYSCOHADA harmonised financial-statement package, NIF, identification sheet and annexes, plus depreciation by acquisition year. An enterprise operating in Mali and other states declares global profit with its Mali activity declaration; an enterprise whose head office is abroad has additional balance-sheet/general-expense attachments. These are the source requirements, not confirmation of today's filing template or accounting standards implementation. [LPF arts. 57, 60–64](https://www.dgi.gouv.ml/CGI/).

Real-normal instalments fall in the last fifteen days of March, July and November. Real-simplified instalments have explicit last dates of 31 March, 31 July and 30 November. New enterprises have distinct forecast/capital rules. The balancing payment is due at the profit-declaration deadline. A taxpayer seeking to stop further instalments needs the source declaration fifteen days before the next due date and must consider the minimum. [LPF arts. 276–285](https://www.dgi.gouv.ml/CGI/).

Prepare the prescribed declaration, attachments and payment reconciliation; obtain the actual current form and authorised submission route before any filing. Keep the filed declaration, acknowledgement and payment receipt. Current form identifiers, boxes and authenticated portal steps have not been read. This sequence remains held by the 2026 source gate.

## Penalties and interest

The older LPF art. 66 provides administrative assessment and a 25% increase for non-filing or missing required supporting documents. Article 67 charges 25% of tax on undeclared profit/turnover, increasing to 50% where good faith cannot be accepted, with no such penalty when the undeclared amount does not exceed 10% of the declared profit/turnover. [LPF arts. 65–67](https://www.dgi.gouv.ml/CGI/).

Late/incomplete instalments and late balancing payment carry the separate 10% rules in articles 283–285. Do not add every sanction together or assume these exhaust interest, notice and recovery rules; their current amendments and interaction have not been reconciled. [LPF arts. 283–285](https://www.dgi.gouv.ml/CGI/).

## Cross-border points

The former Guide's payment topics are preserved with the source's distinctions. Dividends carry 10% IRVM, reduced to 7% for companies listed on a CREPMF-approved exchange. Interest is not uniformly 15%: the source distinguishes 6% bond income and qualifying public-bond reductions, 13% on the instruments described in article 42(3), 9% deposits/current accounts, 15% bondholder prizes and 18% other income. Establish the instrument, exemption and recipient before applying any rate. This is an older source classification, not a current treaty table. [CGI arts. 23–42, especially 41–42](https://www.dgi.gouv.ml/CGI/).

For economic remuneration of a person without a permanent professional installation in Mali, articles 94–98 specify the payment scope, including rights and services supplied or used in Mali. Article 96 deducts 50% of gross receipts for services, or 90% for works/supply contracts; article 97 applies its 30% rate to that determined base. Thus a gross-payment rate cannot be selected from the old wording alone. Treaty qualification, characterisation and separate VAT withholding require their own checks. Related-party prices and head-office charges also require the article 80–81 controls. [CGI arts. 44, 80–81, 94–98](https://www.dgi.gouv.ml/CGI/).

## Two worked examples that recompute

Both cases are hypothetical older-source tests, not 2026 client liabilities. Assume ordinary real-normal IS, no rental-property minimum, and that the additional article 86 final-paragraph floor has been separately established below the computed turnover minimum. Otherwise the calculation is incomplete.

**Profit reconciliation and payments.** Accounting profit XOF 18 million includes XOF 2 million unsupported private costs. Add those costs back under the source deduction tests. Taxable profit is XOF 20 million. Tax-exclusive turnover XOF 400 million gives a XOF 4 million minimum, below XOF 6 million profit tax. Three paid instalments of XOF 1 million leave XOF 3 million to reconcile as the balance.

```oa-check
name: Older DGI company source test, profit and instalments
inputs:
  accounting_profit: 18000000
  disallowed_costs: 2000000
  turnover: 400000000
  paid_instalments: 3000000
steps:
  taxable_profit: floor((accounting_profit + disallowed_costs) / 1000) * 1000
  profit_tax: taxable_profit * 0.30
  turnover_minimum: floor(turnover / 1000) * 1000 * 0.01
  assessment: max(profit_tax, turnover_minimum)
  balance: assessment - paid_instalments
expected:
  taxable_profit: 20000000
  assessment: 6000000
  balance: 3000000
```

**Which computation controls at a low margin?** For the same XOF 400 million turnover, compare supported taxable profit of XOF 5 million with XOF 20 million. The low-profit case gives profit tax XOF 1.5 million, so the XOF 4 million turnover minimum controls. In the higher-profit case XOF 6 million controls. The decision is which statutory base determines the assessment, not an election to pay the lower amount.

```oa-check
name: Older DGI company source test, minimum or profit tax
inputs:
  turnover: 400000000
  low_profit: 5000000
  high_profit: 20000000
steps:
  minimum: floor(turnover / 1000) * 1000 * 0.01
  low_profit_tax: low_profit * 0.30
  high_profit_tax: high_profit * 0.30
  low_assessment: max(low_profit_tax, minimum)
  high_assessment: max(high_profit_tax, minimum)
  difference: high_assessment - low_assessment
expected:
  low_assessment: 4000000
  high_assessment: 6000000
  difference: 2000000
```

## Ask the client first

- Which accounting period, legal form, tax regime and express elections apply?
- Are there mining, investment, rental-property or other exemption/stabilisation terms?
- What are reconciled profit, tax-exclusive operating/accessory turnover, expense evidence and losses by origin year?
- Which instalments and other creditable amounts were actually paid?
- Are there foreign operations, related parties, foreign head-office charges or payments abroad, and what instruments/contracts support them?
- Has the operative amendment chain and actual current form been obtained for the intended filing year?

## Sources

| Source and actual scope | URL | Read on |
|---|---|---|
| DGI, CGI and LPF online consolidation; exact articles cited above and their neighbouring provisions, older amendment labels through 2017; not a 2026 consolidation | https://www.dgi.gouv.ml/CGI/ | 2026-11-01; selected chapters read offline, not the entire code |

Not yet confirmed: complete post-consolidation amendment chain, enacted 2026 Annex U and operative 2026 rules; article 86 additional monetary floor computation; current mining/convention rates; current exemptions and treaty relief; current forms, boxes and authenticated filing/payment steps; complete sanction/interest interactions. No 2025 or 2026 continuity is inferred. No current-year approval or accountant attestation is given.

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