Les incitations fiscales et douanières dans le secteur agricole

Les incitations fiscales et douanières dans le secteur agricole

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En application du Plan Structurel Gabon Emergeant (PGSE) et de la politique de développement agricole durable mise en place par le Gouvernement de la République Gabonaise, des lois ont été promulguées, prévoyant des exonérations fiscales et douanières, en vue d’inciter les populations à investir dans le domaine agricole.

Il s’agit de la loi n°22/2008 portant Code Agricole en République Gabonaise et de la  loi n°2/2013 du 6 février 2013 portant extension du régime fiscal et douanier incitatif en faveur des exploitants agricoles.

Ces textes tant au regard des impôts visés qu’au regard du champ d’application des exonérations prévues, mettent en exergue une forte volonté politique de promouvoir et encourager le développement agricole en République Gabonaise.

1.   Les impôts visés

La liste des impôts, taxes, droits, redevances et autres prélèvements exonérés est exhaustive car il s’agit des impôts et taxes à incidence majeure parmi ceux existants en droit Gabonais, à savoir:

– la patente;

– la Taxe sur la Valeur Ajoutée (TVA);

– l’impôt sur les sociétés;

– les taxes foncières ;

– les impôts sur la propriété, plus précisément les contributions foncières sur les propriétés bâties et non bâties (impôts fonciers) ;

– les prélèvements au titre des prestations du Conseil Gabonais des chargeurs;

– les prélèvements au titre de la concurrence et de la consommation.

– les droits, taxes et redevances collectées par les services des douanes.

 

2.    Le champ d’application des exonérations

       a.   La patente:

Cette exonération concerne les principaux acteurs privés du secteur agricole  Elle s’applique donc aux acteurs suivants :

– les exploitants agricoles et les éleveurs pour les opérations de  vente de produits de toutes natures issus de leurs exploitations;

– les syndicats agricoles et d’éleveurs pour les opérations de vente des produits de toute nature issus de leurs exploitations;

– les sociétés d’aménagement des terres agricoles ou des zones économiques agricoles;

– les sociétés agro-industrielles;

– les groupements d’intérêts économiques à vocation agricole.

 

b.   La TVA:

Sont exonérés de TVA:

– les produits du cru des activités agricoles, d’élevage, de la pêche et de la chasse dont une liste non limitative comprenant des aliments de consommation courante  est prévue par la loi portant code agricole et devra être complétée par un arrêté conjoint du Ministre chargé des Finances et du Ministre chargé des Finances de l’Agriculture;

– les biens, matériels et équipements industriels destinés aux activités agricoles y compris pour la transformation de produits;

– les intrants, notamment les engrais, la provende, les produits phytosanitaires et zoosanitaires nécessaires aux activités agricoles.

 

        c.   L’impôt sur les sociétés:

Concernant l’impôt sur les sociétés, il y a contrariété entre la loi de 2008 et la loi de 2013. Etant donné que la loi de 2013 annule toutes les dispositions antérieures contraires, nous retiendrons ainsi les règles qu’elles édictent concernant les entreprises agricoles que sont les coopératives agricoles, les sociétés d’aménagement des terres agricoles, les sociétés agro-industrielles et les GIE à vocation agricole.

Elle prévoit pour ces sociétés une exonération totale pendant cinq (5) ans, y compris le minimum de perception, pour l’ensemble des activités de production, de transformation, de vente locale et d’exportation des produits agricoles.

Au terme de cette période, l’impôt remonte à 25% pendant les dix années suivantes puis, à l’issue de cette période, il est fixé au taux du droit commun, c’est-à dire 30%.

       

        d.   Les impôts fonciers :

Sur ces impôts, un éclairage du législateur est nécessaire car il y’a des différences significatives entre les articles 291 et suivants du Code général des impôts et les dispositions des articles 25 à 27 de la loi n°22/2008 portant Code Agricole en République Gabonaise : ce sont deux régimes parallèles et distincts qui coexistent dans l’ordonnancement juridique gabonais.

Pourtant une conciliation est nécessaire afin de rendre applicables ces mesures fiscales incitatives.

Nous sommes d’avis que deux paramètres sont à prendre en compte : les dispositions du Code agricole sont postérieures à celles du Code général des Impôts et de plus, elles sont plus favorables et issues d’une loi prise spécifiquement pour le secteur agricole.

Nous pensons par conséquent que le  principe général du droit selon lequel la loi spéciale l’emporte sur la loi générale doit être appliqué dans ce contexte particulier.

Par contre, les règles applicables relatives à la base d’imposition et au calcul de l’impôt après la période d’exonération sont précisées dans le Code général des impôts. Au mieux, il conviendrait que le Code général des impôts soit modifié et mis en harmonie avec les dispositions du Code agricole.

Selon les articles 25 à 27 de la loi n°22/2008 portant Code Agricole, l’exonération fiscale sur les terrains ruraux exploités à des fins agricoles  est accordée  tantôt à titre permanent pour les terrains d’une superficie inférieure ou égale à 10 hectares, tantôt à titre temporaire pour les terrains d’une superficie supérieure à 10 hectares. La période d’exonération temporaire court à compter du 1er janvier de l’année suivant celle au cours de laquelle le terrain aura été nouvellement défriché et ensemencé (ou affecté à l’élevage).

Cette période est fixée comme suit :

–   9 ans pour les terrains plantés en hévéa ou en palmier à huile ;

–   8 ans pour les terrains plantés en arbres fruitiers ;

–   7 ans pour les terrains plantés en caféiers ou en cacaoyers ;

–   6 ans pour les autres cultures.

Pour jouir de l’exonération temporaire, le bénéficiaire doit adresser une déclaration écrite au service local des impôts ; déclaration dont le contenu et la forme doivent être précisés par arrêté. Cependant, l’arrêté qui doit préciser la forme et le contenu de cette demande n’existe pas à ce jour est difficilement applicable.

 

        e.   Les droits, taxes et redevances de douane :

L’exonération des droits, taxes et redevances de douane s’applique sur un panel étendu d’importations. Il s’agit des importations suivantes.

  • Les biens d’équipement, les matériaux de construction de bâtiments, les outils,  les pièces détachées et les matières premières destinées à l’activité agricoles.

La loi précise que concernant les véhicules, matériels et machines qui ne sont pas affectés à l’usage exclusif ainsi que ceux qui sont importés temporairement par les exploitants agricoles, le régime applicable est celui de l’admission temporaire normal, ce qui implique que lesdits biens ne peuvent être cédés ou prêtés sans l’autorisation de l’administration des douanes.

  • Les intrants agricoles ou industriels destinés à l’activité agréée.  Un arrêté conjoint du Ministre chargé des finances et du ministre chargé de l’agriculture doit préciser la liste des intrants exonérés. A ce jour, sauf erreur de notre part, cet arrêté n’a pas été pris.

 

f.    Les autres prélèvements administratifs (Concurrence et consommation, Conseil Gabonais des chargeurs) et les taxes foncières (TSIL, TCL)

La loi n’est pas très précise concernant le champ d’application de ses exonérations. Apparemment, elles s’appliquent de manière absolue aux exploitants agricoles ainsi qu’aux entreprises agricoles exonérées d’impôts sur les sociétés.

 

3.   Quelles sont les conditions pour faire valoir le bénéfice de ces exonérations?

Pour bénéficier de ces exonérations, les acteurs privés du secteur agricole doivent avoir préalablement obtenu du responsable départemental de l’agriculture un état d’évaluation des travaux réalisés et un agrément technique délivré par le ministre chargé de l’agriculture, de l’élevage et du développement rural après avis de la commission compétente.

Ces avantages ne concernent pas uniquement la PME agricole et sont étendus par la loi du 6 février 2013 portant extension du régime fiscale et douanier aux entreprises agricoles réalisant un minimum d’investissement de 150 millions de francs CFA et un minimum d’effectifs de trente personnes de nationalité gabonaise, notamment :

–      Les sociétés coopératives agricoles ;

–      Les sociétés d’aménagement des terres agricoles ou des zones économiques agricoles, les sociétés agro-industrielles ;

–      Les groupements d’intérêt économique à vocation agricole.

 

Il convient de préciser que la loi du 19 décembre 2008 portant développement économique agricole durable que “toute personne physique ou morale exerçant à titre habituel des activités agricoles est tenu de déclarer cet exercice à l’administration.”

Cette déclaration doit comporter toutes les informations de l’exploitation sur laquelle les activités sont exercées et donne lieu à un numéro d’enregistrement au registre du ministère de l’agriculture.

 

Nous notons que les textes ne prévoient pas un échange d’informations entre le Ministère de l’agriculture et l’administration des impôts. Aussi, nous pensons que pour pallier cette carence, la personne qui exerce une activité agricole doit demander expressément le bénéfice de ces exonérations aux impôts en mentionnant dans sa demande son numéro d’enregistrement au ministère de l’agriculture et en joignant à sa demande l’agrément technique délivré par le Ministère de l’agriculture.

Nous militons toutefois pour une meilleure fluidité de l’information entre le Ministère de l’Agriculture et l’administration des impôts. Il est possible d’envisager que la liste des agriculteurs enregistrés au Ministère de l’agriculture et agréés soit transmise à l’administration des impôts.

Par ailleurs, certaines zones d’ombre des lois existantes méritent éclaircissement concernant notamment les impôts fonciers. De même que les textes d’application prévus doivent être élaborés et pris dans les meilleurs délais afin que les dispositions applicables en matière d’exonération fiscale aient toute leur cohérence dans le secteur agricole.

 

K. BOUSSOUGOU

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