Faced with the persistent cost of bank credit and with a policy rate held at 7% by the Central Bank of Tunisia, an increasing number of executives are rediscovering a funding source as old as it is discreet: the shareholder’s current account.
Flexible in its implementation and free from any formalities of incorporation, this instrument nonetheless remains one of the areas most closely scrutinized by the tax administration and one of the most reliable indicators of the quality of governance within a company.
A Growing Recourse
The average monthly rate on the money market settled at 6.99% in May 2026, its lowest level since June 2022, in the wake of the Central Bank of Tunisia lowering the policy rate from 8% to 7% at the end of December 2025.
Banks applying margins that can reach up to seven percentage points above this reference rate mean that the effective cost of an operating loan or an investment loan remains high for a large portion of Tunisia’s productive fabric, particularly small and medium-sized enterprises facing tightened lending criteria.
In this context, the shareholder’s current account emerges as a rapid liquidity alternative, without real collateral, without going before an extraordinary general meeting, and without capital dilution, unlike a classical capital increase whose statutory formalities significantly extend the time required to mobilize funds.
A Dual Framework: Contractual and Tax
The shareholder’s current account draws its freedom from the contractual principle laid down in Article 2 of the Commercial Companies Code, but its tax treatment adheres to a much more constraining framework, established by Article 48-VII of the Code of Income Tax for individuals and of the corporate tax.
When the shareholder advances funds to the company, the remuneration of this advance is deductible from the taxable result only under three cumulative conditions: the share capital must be fully paid up, the total amount of advances eligible for remuneration is capped, for all shareholders, at 50% of the share capital, and the interest rate allowed for tax purposes must not exceed 8% per year.
Any breach of one of these ceilings triggers an extra-accounting reintegration of the excess portion, which becomes permanently non-deductible for the company while remaining taxable for the benefiting shareholder.
The mechanism also works in reverse. When the company provides funds to a shareholder, this current account becomes a debtor, and Article 48-VII then provides an additional interest taxable at a rate of 8%, calculated ex officio even if no interest has been charged. This anti-abuse provision aims to prevent a shareholder-manager from financing personal consumption through corporate cash that escapes taxation.
The Regulated Agreement, a Governance Tool
