These provisions, provided for in Articles 52, 53 and 54 of the draft bill, also address the waiver of certain tax penalties owed by the CNRPS and the strengthening of the equity of the establishments concerned.
The essentials
- Article 52 : waiver of audit and late recovery penalties related to the CNRPS’s tax debts registered up to December 31, 2026.
- Article 53 : the State would assume the debts of four public establishments and enterprises toward the CNRPS, as of end-2026.
- Financial compensation : the receivables transferred to the State could be offset against the CNRPS’s tax debts toward the State.
- Article 54 : the Minister of Finance would be authorized to participate in equity-strengthening operations for the four affected structures.
The CNRPS would benefit from tax penalty waivers
Under Article 52 of the 2027 Finance Bill, it is proposed to waive the tax control penalties and the late collection penalties related to the CNRPS’s tax debts.
These measures would apply to debts registered in the tax authorities’ records up to 31 December 2026.
However, the text specifies that this waiver would not entail reimbursement of amounts already paid nor a revision of their accounting.
The operation would also be tax-neutral with respect to corporate income tax.
This provision aims to lighten certain tax charges borne by the CNRPS, without envisaging, in the elements presented, a general waiver of the principal of its tax debts.
Four establishments and public enterprises affected by the debt relief
Article 53 provides that the State would substitute itself for four public establishments and enterprises to settle their debts to the CNRPS, registered as of 31 December 2026.
The structures concerned are :
| Establishment or enterprise | Planned measure |
|---|---|
| Office of State Lands (OSL) | Debt assumption and increase of allocated funds |
| Tunisian National Railways Company (SNCFT) | Debt assumption and increase of allocated funds |
| Tunis Transportation Company (Transtu) | Debt assumption and increase of allocated funds |
| National Company for Pulp and Alfa Paper (SNCPA) | Debt assumption and increase of capital |
The proposed mechanism aims to address the financial commitments of these structures toward the pension fund as part of a State intervention.
Article 53 also provides for the possibility of offsetting the debts of these companies transferred to the State against the tax claims held by the State on the CNRPS.
This operation would be tax-neutral with respect to corporate income tax.
A strengthening of equity provided for by Article 54
In addition to settling the debts, Article 54 of the 2027 Finance Bill authorizes the Minister of Finance, acting on behalf of the State, to participate in equity-strengthening operations for the concerned establishments and enterprises.
The text distinguishes two mechanisms :
For the Office of State Lands, SNCFT and Transtu, it provides for the State to subscribe to increases in the funds allocated to them.
For the National Company for Pulp and Alfa Paper (SNCPA), the intervention would take the form of a subscription to an increase in its capital.
In both cases, the amounts would be capped at the level of the debts transferred to the State under the commitments of these establishments and enterprises toward the CNRPS.
These operations would, if the provisions are adopted, accompany the handling of the indebtedness by strengthening the financial structure of the entities concerned.
A financial restructuring framework still at the project stage
The Articles 52, 53 and 54 of the 2027 Finance Bill thus propose a framework organized around three mechanisms: waiving certain tax penalties, State debt assumption and strengthening the equity capital of several public establishments and enterprises.
However, the information available does not specify the amounts of debt involved, nor the overall financial impact of these operations on the State’s accounts, the CNRPS, and the beneficiary structures.
Moreover, these provisions are currently included in the 2027 Finance Bill. Their implementation remains conditioned on the final adoption of the text and its entry into force.
If approved, these measures could help clarify the financial relations between the State, the CNRPS, and the affected public establishments and enterprises, without by themselves guaranteeing a lasting improvement in their financial situation.
