The publication of Joint Notice No. 13/2026 by the General Directorate of Tax Studies and Legislation (DGELF) on June 11, 2026, marks a major step in the implementation of the new wealth tax established by Section 88 of the 2026 Finance Act.
This text provides the expected clarifications on the procedures for applying this tax and establishes the administrative guidelines regarding the determination of the tax base, the assets subject to the tax, and the conditions for exemption.
This reform marks a significant shift in Tunisia’s approach to wealth taxation. Indeed, the previous approach of limiting taxation to real estate has now given way to a comprehensive approach that encompasses all assets held by individuals, including real estate, personal property, and financial assets.
1. Scope of Application, Tax Threshold, and Progressive Tax Scale
The wealth tax applies to individuals whose total net worth reaches or exceeds the threshold of 3 million Tunisian dinars (MDT), as determined as of January 1 of the tax year.
The assessment of net worth takes into account the assets held by the taxpayer as well as those belonging to the taxpayer’s spouse and minor dependent children.
The tax authority uses a progressive tax scale consisting of two brackets:
- 0.5% applicable to the portion of net assets between 3 MDT and 5 MDT;
- 1% applicable to the portion exceeding 5 MDT.
While the general principle seems relatively clear, the main challenges lie in identifying the assets included in the tax base and in interpreting the exemption provisions set forth in the regulations.
2. Bank Deposits: An Important Distinction Between Savings and Cash
One of the major contributions of the Joint Note concerns the tax treatment of financial assets held with banks and financial institutions.
Contrary to a broad interpretation of the exemption provided for in Article 88 of the Finance Act, the tax authorities adopt a restrictive interpretation by distinguishing between savings income that qualifies for an exemption and investments treated as taxable cash equivalents.
The following, in particular, are excluded from the tax base:
- traditional savings accounts held at banks or the Post Office;
- home savings accounts and education savings accounts;
- investment savings accounts intended to finance projects or reinvest capital;
- life insurance policies, Takaful policies, and retirement savings plans.
Conversely, certain financial instruments remain taxable, including:
- checking accounts;
- term deposit accounts;
- certificates of deposit.
This distinction is a significant consideration for taxpayers with substantial financial resources. Cash held on a short-term basis in checking accounts or in interest-bearing investments can thus significantly increase the taxable base for wealth tax purposes.
3. Equity Interests in Companies: The Concept of Business Assets at the Heart of the Framework
The Joint Notice confirms that shares and equity interests are, in principle, considered movable assets subject to wealth tax.
However, an exemption may apply when these securities represent business assets, subject to certain conditions.
For corporations such as SA, SARL, and SUARL, the exemption is subject, in particular, to a majority ownership requirement: the taxpayer, together with his or her minor children, must directly hold at least 50% of the share capital.
Two important limitations emerge from this doctrine:
- Direct ownership is required: equity interests held through holding companies or intermediary structures do not qualify for the exemption;
- The 50% threshold is a decisive condition: a partner holding 49% of a company’s capital may have the entirety of their interest included in the taxable base, even if that interest represents their primary professional asset.
With regard to partnerships, particularly general partnerships (SNCs) and certain similar entities, the tax authorities take a more favorable approach. Holdings in such entities may qualify for an exemption when the partnership engages in an actual business activity, with no minimum ownership threshold required.
4. Valuation of Securities: A Major Challenge for Unlisted Investments
Determining the value of securities is also a sensitive issue.
For publicly traded securities, the rule is relatively simple: the value is equal to the closing price recorded on December 31 of the year preceding the tax assessment.
For unlisted securities, the Common Rating Guide favors a valuation based on book value, particularly through the company’s net worth.
Although this method can limit discrepancies related to market valuations, it requires special attention. Factors such as revaluation adjustments, provisions, accumulated earnings, and partners’ current accounts can have a significant impact on the value determined.
Rigorous accounting records are therefore essential to safeguard the taxpayer’s tax position in the event of an audit.
Conclusion: Toward a New Approach to Wealth Management
Joint Notice No. 13/2026 provides a more precise framework for the implementation of Tunisia’s new wealth tax, while raising new challenges in the area of estate planning.
Decisions regarding cash management, the nature of financial investments, and the method of holding professional equity interests are now becoming essential elements of the tax strategy for the taxpayers in question.
For certified public accountants, tax advisors, and financial professionals, their role is no longer limited to preparing tax returns. It now involves a comprehensive analysis of a client’s assets, the identification of tax risks, and guidance on implementing appropriate structures to ensure compliance and optimization in accordance with current regulations.