# Guinea VAT, timing and input-credit method v1.1

> **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.

## Who this applies to

**Governing-version prerequisite:** establish the operative CGI provisions, cited amendments and DGI interpretation for the actual supply/return period, including any October 2026 rectification. The final October promulgated text/effect is unretrieved. If applicability is unresolved, label the result hypothetical source-version analysis and stop before a live registration, invoice, deduction, return or payment conclusion. Do not infer that the unretrieved law was not enacted.

Use for an ordinary VAT-registered service business or purchaser/reseller of goods, with its actual supplier/recipient status and territorial classification established. CGI 358 covers independently conducted economic activity; employment/subordinate remuneration is not an independent VAT supply. Public-authority activities and sector/transaction exceptions require their own scope analysis. This method produces a registration decision record, transaction/timing register, output/input workpaper, credit reconciliation and draft return evidence. [CGI 358-358 quater](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).

Test franchise before charging VAT. Article 359 generally places domestic taxpayers with preceding-year turnover below GNF 1,000,000,000 in franchise; exactly that amount is not below it. A taxpayer that previously reached the threshold returns only after two consecutive years below, subject to its actual option status. Non-established taxpayers do not receive the ordinary franchise under article 359 II. Franchise taxpayers cannot charge or deduct VAT and must use the statutory no-VAT invoice wording “TVA non applicable - article 359 du CGI”; a customer's request does not change registration. [CGI 359](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).

Article 360 permits a VAT option where preceding/current-year turnover, preceding-year investments or estimated current-year investments meet the stated GNF 500,000,000 condition. It requires the actual application/examination process; qualification is not an automatic election. Obtain NIF and VAT-key evidence. Under article 373 quater IV an applicant awaiting its VAT key cannot issue VAT invoices or deduct VAT. [CGI 360,373 quater](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).

## Rates, bands and thresholds

| Item | Rate, amount or condition | Official source |
|---|---|---|
| Standard taxable supply | 18% of the VAT-exclusive base | [CGI 373 I/III](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf) |
| Zero rate | Direct goods exports and directly related services; international goods/passenger transport and specified qualifying maritime/aircraft operations under article 373 II, with their conditions | [CGI 373 II](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf) |
| Domestic franchise turnover | Below GNF 1,000,000,000 in the preceding year; return after two consecutive below-threshold years for former threshold taxpayers | [CGI 359](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf) |
| Option qualification | At least GNF 500,000,000 under one of article 360's turnover/investment routes; not automatic registration | [CGI 360](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf) |
| Unchanged-goods reseller input imputation | Eligible input including carried credit capped at 90% of monthly output VAT where the activity is wholly or partly buying/reselling goods unchanged | [CGI 375 IV](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf) |
| Listed-client VAT withholding | 50% of VAT on the covered taxable operation; full output remains declared | [CGI 373 ter](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf) |
| Ordinary refund claim minimum | GNF 100,000,000, with eligible claimant status and three consecutive credit months | [CGI 388 II](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf); [LFI 2025 art. 28](https://dgb.gov.gn/wp-content/uploads/2025/02/Loi-de-Finances-Initiale-2025.pdf) |

An ordinary service located abroad under the territorial rules is not automatically a zero-rated export. Article 374 II 3 separately allows associated input recovery for qualifying services located outside Guinea that would qualify if supplied domestically. Article 362 exemptions and later sector/product concessions need the actual provision and conditions; the old description “essential goods/services” is not a usable classification. Exemption generally does not confer the same input entitlement as zero rating. [CGI 361 ter-duodecies,362,373-374](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).

## The base

### Classify and time each supply

1. Record supplier and customer establishment/registration, supply type, location, contract, goods movement or service facts, price terms, invoice, receipts and any election. Goods territoriality follows article 361 ter's location/dispatch/installation rules; the general service rule in article 361 quater looks to the recipient's establishment, with special property, physical-performance, transport and telecom rules elsewhere. Do not decide territory from a foreign bank account or customer address alone. [CGI 361 ter-duodecies](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).
2. Establish taxable, zero-rated, exempt or outside-scope treatment from the actual law before applying a rate. Preserve export/customs evidence or the exact exemption basis; refer special equipment, vehicles, property/development and electronic-service cases for their specific conditions. Later electrical/vehicle concessions are not a general exemption for all goods. [CGI 362,373](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf); [DGI précis §5.1](https://dgi.gov.gn/wp-content/uploads/2026/04/Guinee-Precis-fiscal-2026.04.10-VF.docx).
3. Determine exigibility separately from invoice date and the chargeable event. Imports become exigible on release for consumption. Ordinary services become exigible on partial/full receipt, including advances even before performance, unless a valid debit-basis election applies. Earlier receipts still trigger tax under the debit election. Public-entity goods purchases have their own receipt timing. [CGI 365-366 bis](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).
4. The available enacted edition visibly truncates ordinary-goods article 366 III 2 after “lors de la”. DGI guidance supplies delivery/earlier-payment interpretation, but the statutory printing defect remains a source limitation. Resolve that text/interpretation for the actual goods return; do not substitute invoice date as a universal legal rule. The ordinary service-cash example below rests on the complete article 366 III 4. [CGI 366](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf); [DGI précis §5.1.3](https://dgi.gov.gn/wp-content/uploads/2026/04/Guinee-Precis-fiscal-2026.04.10-VF.docx).
5. Build the VAT-exclusive consideration including the statutory incidental costs and taxes other than VAT, less qualifying documented discounts. For imports use customs value plus other customs-liquidated duties/taxes, excluding VAT. For a standard-rate tax-inclusive cash amount, VAT is `cash_received × 18 / 118`; reconcile the remaining cash to the VAT-exclusive amount. Related-party/non-cash values need the statutory market-value method, not an unsupported contract number. [CGI 367,373 III](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).

### Build output, eligible input and the credit reconciliation

6. Include all output VAT exigible in the month and separately identified reverse-charge output and adjustments. Apply the independent [invoice-field control](gn-vat-invoice-control.md). The 2025 amendment also provides manual e-Tax invoice capture or automatic transmission through the e-TVA/SAFIG API; the source establishes that channel requirement, not a tested software integration here. [CGI 373 bis](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf); [LFI 2025 art. 27, CGI 383 V](https://dgb.gov.gn/wp-content/uploads/2025/02/Loi-de-Finances-Initiale-2025.pdf).
7. Deduct only legally recoverable VAT on real business supplies used for deductible operations, with a valid supplier invoice carrying the required article 383 particulars, or customs documents/payment naming the actual importer. Incorrectly invoiced VAT remains payable by its issuer but is not deductible by the recipient. Reverse-charge deduction also requires the recipient tax to have been paid under article 375 I 1 d. Do not treat reverse charge as automatically neutral. [CGI 373 bis V,374-375](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).
8. The deduction right arises when the supplier's tax becomes exigible, not automatically when an unpaid service invoice arrives. Reconcile the purchase/payment register. A missed deduction can be repaired by a later declaration filed no later than 31 December of the year after omission, subject to proof the invoices were paid. [CGI 374 III,375 V](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).
9. Apply exclusions before the arithmetic. Article 376 excludes specified accommodation/meals/entertainment, passenger transport/hire, gratuitous supplies, telephone/internet and petroleum costs, subject to its explicit exceptions; article 377 excludes passenger/mixed vehicles subject to its exceptions. Identify the exact clause before allowing any exception. Mixed economic/non-economic or taxable/exempt use requires articles 377 bis/ter and 378 allocation/pro rata; do not deduct the entire invoice merely because it is addressed to the business. Detailed coefficients and capital/bad-debt adjustments remain a separate method. [CGI 376-381](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).
10. For a business wholly or partly buying/reselling goods unchanged, impute eligible input VAT **including brought-forward credit** only up to 90% of monthly output VAT; carry the unused balance. For the pure ordinary service case without that activity, apply the normal eligible-input/carry offset. Keep output, current eligible input, opening credit, deduction used, closing credit and net payable separately. Export traders, mixed activities and withholding combinations require their full ordering/adjustment analysis before applying a shortcut. [CGI 375 III-IV](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).
11. Reconcile listed-client withholding separately. Article 373 ter covers the state, local authorities, public bodies/enterprises, mixed-economy companies, telecoms, petroleum import/storage/distribution companies and mining companies. The supplier declares full output and the supported withholding credit, with the required receipt. It does not halve the sale or simply invoice half the VAT. Do not assume this withholding applies to every business customer. [CGI 373 ter](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).

### Credit carry and refund control

Ordinary excess deductible tax carries to the next month; a refund is an exception. CGI 387 II as amended in March 2026 permits qualifying zero-rate operators; eligible capital-asset claims within their asset-VAT limit; exclusively mining/petroleum research/exploitation title holders; and taxpayers exclusively on externally financed Finex contracts whose VAT is paid by CTSS. Test the actual category and article 388 conditions before proposing cash repayment. [CGI 387](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf); [LFI 2026 art. 11](https://dgb.gov.gn/wp-content/uploads/2026/04/Loi-de-Finances-Initiale-2026.pdf).

The claim requires three consecutive credit months and at least GNF 100,000,000. The 2025 amendment makes applications exclusively electronic through e-Tax/SAFIG; the précis's paper-post/receipt text is stale against that provision. Remove a claimed refund from later imputation so the same credit is not both claimed and carried. Article 387 bis also sets a twelve-consecutive-month lapse rule and a below-minimum exception; keep a credit-ageing review and resolve its application to the claimant's facts. Do not assume credits carry forever or write one off without checking the applicable category and conditions. Full refund documents, guarantees, review and implementation are not completed here. [CGI 387 bis,388 II/IV](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf); [LFI 2025 art. 28](https://dgb.gov.gn/wp-content/uploads/2025/02/Loi-de-Finances-Initiale-2025.pdf); [DGI précis §5.1 refund subsection](https://dgi.gov.gn/wp-content/uploads/2026/04/Guinee-Precis-fiscal-2026.04.10-VF.docx).

## Deadlines and filing

File monthly and pay the net amount at filing, no later than the tenth of the following month under LFI 2025 article 13 replacing CGI 373 sexies I. The old fifteenth-day date is superseded. Use the e-Tax/SAFIG forms and required sales/deduction schedules; the 2025 deduction annex includes prior-month purchases from VAT and non-VAT suppliers. Preserve supplier identity/NIF/key, invoice numbers/dates, nature, service-payment dates, deductible VAT and customs liquidation evidence as applicable. A nil month still requires a declaration; credit months need their credit details, rather than an indiscriminate “néant”. [LFI 2025 arts. 13,25](https://dgb.gov.gn/wp-content/uploads/2025/02/Loi-de-Finances-Initiale-2025.pdf); [CGI 373 sexies IV-VI](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).

Reconcile registration/key status, output by exigibility period, legal invoice and import evidence, recoverability/limitations, opening and closing credits, withholding receipts and tax payable before submission. Retain the signed workpaper, filed return/annexes, acknowledgement, payment/withholding evidence and credit/refund roll-forward. Current authenticated fields, submission screens and receipt implementation have not been inspected; an API provision or prepared spreadsheet is not proof of filing.

## Penalties and interest

CGI 373 bis makes an issuer liable for VAT wrongly printed on its invoice and denies that VAT to the recipient; the same provision also addresses an omitted-tax invoice through tax calculated inside the billed amount. Do not correct this by silently editing the recipient's spreadsheet. Obtain the appropriate supplier correction and legal treatment. Complete current VAT late-filing, payment, deduction and invoice sanctions/appeals remain unresolved; do not import a rate from another country's VAT or the CNSS surcharge. [CGI 373 bis V-VII](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).

## Cross-border points

A Guinea VAT-registered recipient can be liable under article 373 bis II for a taxable supply by a non-established supplier where the statutory establishment/receipt conditions hold. A non-resident supplier required to register but not established in Guinea must appoint the article 373 quinquies representative, subject to its conditions and joint responsibility. These are conditional branches, not universal reverse charge for all B2B buyers or universal representation for every foreign supplier. Imports have the separate actual-importer rule. [CGI 373 bis II-III,373 quater-quinquies](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf).

Apply territoriality first, then liability, rate, timing and input entitlement. Special property/transport/telecom/electronic services, foreign-currency dates/rates, exports and treaty interactions require the relevant verified rules and records. No current exchange-rate number or automatic cross-border deduction is supplied.

## Two worked examples that recompute

A registered domestic trader resells goods unchanged, with monthly standard-rate sales GNF 100,000,000 excluding VAT, eligible input VAT plus opening credit GNF 20,000,000, and no exports or withholding. Output is GNF 18,000,000. The 90% cap permits GNF 16,200,000 input imputation, leaving GNF 1,800,000 payable and GNF 3,800,000 carried credit. The decision is to apply the trader rule: subtracting all available input would wrongly show no payment and a GNF 2,000,000 credit. Actual goods timing and all governing source versions are assumed established.

```oa-check
name: Unchanged-goods reseller applies input-credit imputation cap
inputs:
  validated_monthly_taxable_sales_ht: 100000000
  eligible_input_and_opening_credit: 20000000
steps:
  - output_vat: validated_monthly_taxable_sales_ht * 0.18
  - input_cap: output_vat * 0.90
  - input_used: min(eligible_input_and_opening_credit, input_cap)
  - net_payable: output_vat - input_used
  - closing_credit: eligible_input_and_opening_credit - input_used
  - wrong_uncapped_credit: max(eligible_input_and_opening_credit - output_vat, 0)
expected:
  output_vat: 18000000
  input_used: 16200000
  net_payable: 1800000
  closing_credit: 3800000
  wrong_uncapped_credit: 2000000
```

A pure service business has no debit election, trader activity, reverse charge or client withholding. Its invoice is GNF 200,000,000 plus GNF 36,000,000 VAT, total GNF 236,000,000; it receives only GNF 59,000,000 including tax in the month. This receipt contains GNF 50,000,000 net and GNF 9,000,000 VAT. Other independently eligible input VAT GNF 2,000,000 is deductible in that month, so net payable is GNF 7,000,000. The invoice alone does not trigger the entire GNF 36,000,000 under the ordinary cash rule. The GNF 177,000,000 unpaid balance follows later receipts; this case is not an election to ignore a valid debit-basis option.

```oa-check
name: Service receipt timing instead of whole invoice output
inputs:
  invoice_net: 200000000
  actual_ttc_receipt: 59000000
  independently_eligible_input: 2000000
steps:
  - full_invoice_vat: invoice_net * 0.18
  - full_invoice_gross: invoice_net + full_invoice_vat
  - receipt_vat: actual_ttc_receipt * 18 / 118
  - receipt_net: actual_ttc_receipt - receipt_vat
  - payable: receipt_vat - independently_eligible_input
  - unpaid_gross: full_invoice_gross - actual_ttc_receipt
expected:
  full_invoice_vat: 36000000
  full_invoice_gross: 236000000
  receipt_vat: 9000000
  receipt_net: 50000000
  payable: 7000000
  unpaid_gross: 177000000
```

## Ask the client first

- What NIF/key, franchise history, turnover/investment and actual option or debit-election evidence apply?
- What supply, supplier/recipient establishment, transport/location, contract and rate/exemption/export evidence govern each operation?
- When were goods/services delivered, invoices issued and cash/advances received or paid, and what source version governs those dates?
- Is the business wholly or partly a reseller of unchanged goods, mixed-use/exempt operator or special-sector claimant?
- What invoices/import documents, recoverability evidence, opening credits, withholding receipts and correction/refund claims exist?
- What filed returns, annexes, acknowledgements, payments and unresolved assessment/credit-ageing issues remain?

## Sources

| Official source and portions actually read | Read on |
|---|---|
| [DGI enacted CGI base](https://itie-guinee.org/wp-content/uploads/2022/01/NOUVEAU-CODE-GENERAL-DES-IMPOTS.pdf), relevant VAT arts. 358-388 and neighbouring scope/timing/base/credit provisions; ordinary-goods 366 III 2 is visibly incomplete in the original publication. | 2026-11-01 |
| [LFI 2025](https://dgb.gov.gn/wp-content/uploads/2025/02/Loi-de-Finances-Initiale-2025.pdf), arts. 13,23,25,27-28: tenth-day filing, electronic administration, annexes, invoice channel and electronic-only refunds, read against original scanned clauses. | 2026-11-01 |
| [LFI 2026](https://dgb.gov.gn/wp-content/uploads/2026/04/Loi-de-Finances-Initiale-2026.pdf), art. 11 refund categories and art. 13 invoice particulars, full operative clauses with neighbours and signed promulgation evidence. | 2026-11-01 |
| [DGI Précis fiscal 2026, 10 April](https://dgi.gov.gn/wp-content/uploads/2026/04/Guinee-Precis-fiscal-2026.04.10-VF.docx), relevant §5.1 scope, timing, computation, deduction, filing and refund paragraphs. Paper-refund routing is superseded by the enacted 2025 electronic requirement. | 2026-11-01 |

Not yet confirmed: October 2026 final promulgation/text/effect and applicability of every source version; full ordinary-goods exigibility text beyond the available printing defect; detailed exemption/product classifications and later electrical/vehicle concessions; special property/developer/margin/telecom/electronic-service regimes; mixed-use/pro-rata and capital/bad-debt correction methods; withholding/trader/export ordering; all refund documents, guarantees, lapse/category interactions and authenticated portal processes; foreign currency rates and complete VAT sanctions/appeals. Ordinary VAT methods are expanded, but the domain and country pack remain partial.