Guinea taxes residents on worldwide income and non-residents on Guinea-source income only. Guinea operates a self-assessment system for corporate tax, with the domestic tax authority conducting post-filing review.
Guinea's tax year is the calendar year.
30% standard rate.
Flat/top rate 20%.
18% standard rate.
For companies, entities registered under Guinean law, branches of foreign companies, and permanent establishments are considered resident. Unusually, both resident AND non-resident corporations are subject to tax on Guinean-source income specifically - Guinea does not tax resident corporations on worldwide income the way most jurisdictions on this site do; the corporate tax base is territorial regardless of residence status. Separately, individual residency in practice is generally treated as habitual abode or presence exceeding 183 days.
A non-Guinea-resident entity has a Guinea permanent establishment through a fixed place of business or a dependent agent habitually concluding contracts in Guinea on the entity's behalf, following the OECD Model Treaty definition as applied under Guinea's domestic law and any applicable tax treaty.
No CFC-style attribution provision was found in Guinea's General Tax Code (Code General des Impots, modernized under Law No. L/2021/032/AN, in force since 1 January 2022, further updated for the 2025 finance law). Guinea's active anti-avoidance focus is transfer pricing rather than CFC. Per the Ministry of Budget's own official site, Guinea's Budget Minister chaired a dedicated workshop on transfer pricing in the mining sector on 26 January 2026, and the Code itself contains provisions on indirect control and dependency between related enterprises (Article 15 and related provisions addressing permanent-establishment profit attribution and share transfers conferring indirect control over a Guinea-established legal entity). This is consistent with Guinea's corporate tax system taxing resident companies on a territorial basis, which structurally reduces the need for a CFC-style anti-deferral rule.
No statutory thin capitalization ratio is identified in available sources for Guinea specifically.
Guinea does not use an elective check-the-box classification system; entity classification generally follows the entity's actual legal characteristics under the French-derived legal tradition shared across the region. Guinea does not have a comprehensive ATAD2-style anti-hybrid regime.
No foreign bank account or foreign financial asset reporting regime exists requiring residents to separately disclose foreign accounts; foreign income is reported through the standard annual tax return.
Guinea does not provide a broad participation exemption for foreign dividends in the European sense, consistent with the transfer-pricing-focused (rather than exemption-focused) anti-avoidance framework already confirmed elsewhere on this page; relief from double taxation is available primarily through Guinea's foreign tax credit system where one exists.
Guinea has a foreign tax credit mechanism for foreign tax paid on foreign-source income also taxed domestically, capped at the domestic tax otherwise due on that income.
Guinea maintains a network of 3 double taxation agreements, including a confirmed treaty with France (per France's own official DTT partner list).