Executive summary

In October 2025, the Algerian General Directorate of Taxes (DGI) issued two circulars clarifying the obligations and rights for audited companies and tax officials as well as on-site tax audit procedures.

Circular No. 64 MF/DGI/LF2025, dated 14 October 2025 (Circular 64), gives tax authorities stronger rights to access information within 20 working days by removing professional secrecy barriers. Failure to comply will result in a fine up to 4,000,000 Algerian Dinar (DZD4m).

Circular No. 68/MF/DGI/DIVCEF/LF25, dated 27 October 2025 (Circular 68), allows taxpayers subject to on-site tax audits to request an arbitration session separately from submitting an answer to the notification. Circular 68 requires auditors to formally notify taxpayers when the on-site tax audit is closed even if no adjustments are identified, delivering this notification either via registered mail (recommended) or hand delivery with acknowledgment of receipt.

Key provisions

Communication rights

The 2025 Algerian Financial Law, via articles 96 to 103, expands the communication rights of tax authorities, allowing access to information for determining tax bases, collecting taxes and implementing international treaties and agreements related to tax cooperation. Currently, professional secrecy cannot be invoked against tax agents, although lawyers are exempt from disclosing client information related to legal advice or ongoing actions. Public and private entities must also share information with tax auditors without claiming professional secrecy.

Algerian tax authorities may exercise their right to communication through written requests to relevant companies and organizations, which must be sent via registered mail or delivered in person with acknowledgment of receipt. This right covers all necessary files, records, accounting documents and invoices. Circular 64 also requires the taxpayer to retain documents for six or 10 fiscal years, depending on the nature of the document.

Financial and banking institutions must notify the tax administration of account openings, closures or modifications, providing details about account holders and their legal contributions. The institutions are also required to identify the beneficial owners of these accounts and provide the information included in any account change notifications.

Banks and financial institutions must submit responses to these requests to tax administration within 20 working days of receiving a request. Refusal to provide the information, books, documents and records requested by the tax administration carries a tax fine of DZD2m; prior to the 2025 Financial Law, fines ranged from DZD5k to DZD500k and applied only in case of noncommunication of documents.

Other sanctions that may be imposed for noncompliance with Algerian tax administration requests for information and documents and collected through individual assessments include the following:

• A late response incurs a daily penalty of DZD50k, up to a maximum of DZD2m.
• Partial or insufficient communication of requested information results in a fine of DZD50k for each deficiency, also capped at DZDm.
• Providing incorrect information leads to a fine of DZD2m.
• Repeat offenses double the fines and penalties, with a maximum limit of DZD4m.
• Refusal to provide required information or destroying documents before the legal retention period ends results in a tax fine of DZD2m.

Right for taxpayers to request arbitration if subject to an on-site tax audit

To strengthen the safeguards for taxpayers subject to on-site tax audits (general and specific accounting verification), Circular 68 provides clarifications related to article 20-6 of the Algerian tax procedures code and allows the taxpayer to submit an arbitration request in a separate correspondence, distinct from the response to the initial notification of adjustments, within the legally mandated response timeframe.

Requirement of auditor's notification absent adjustments

The article 90 of the Financial Law for 2025 requires tax auditors to provide a final notification even if no reassessment is made. Circular 68 provides that this notification must be delivered either by recommended letter or by hand with proper acknowledgment of receipt provided.

The law also indicates that the same rule applies in case of punctual verification of books (i.e., a type of tax audit dedicated to a specific tax or taxes or a specific fiscal year).

Failure of tax auditors to provide a final notification to the taxpayer not only leaves the taxpayer in a state of uncertainty regarding the finalization of the tax audit but also stops the four-fiscal-year prescription period for tax debts.

Therefore, the Circular mandates that auditors formally notify taxpayers about their conformity and audit's closure without any adjustments to their tax situation, if no irregularities are identified.

Effective date

These provisions will take effect for all audits initiated and requests for communication starting from 1 January 2025.