We know that in order to be able to benefit from a tax treaty to prevent double taxation, a company must be subject to tax because of its status or its activity. In application of this principle, the Conseil d’Etat refused to a company exempt from corporation tax because of its status as a financial company the benefit of the Franco-German tax treaty and therefore the obtaining of the rate of withholding at the conventional source (CE November 9, 2015, n° 370054).
Tunisia offered an incentive scheme to companies that provided services to foreign companies: it allowed them to deduct from their taxable results in Tunisia the profit made abroad. This regime could lead to a total exemption if the Tunisian company carried out its activity only internationally. However, it was limited in time to 10 years.