The implementation of provisions relating to the continuing vocational training tax and the apprenticeship tax, as introduced and clarified by the Code of Direct Taxes and Assimilated Taxes (CIDTA) and the interministerial order of 21 December 2022, continues to raise many questions among employers, accountants, tax specialists and business managers.

This article provides clear, reasoned and legally grounded answers to the main practical questions raised on these two taxes, drawing on the applicable legislative, regulatory and administrative texts.

1. Are social contributions deducted from the payroll?

No.

Article 196 bis 2 of the CIDTA defines the payroll as:

"the total wages paid to employees before deduction of social contributions, retirement contributions and IRG – wages."

This definition is taken up and confirmed by article 4 of the interministerial order of 21 December 2022, which specifies that the basis of calculation of both taxes consists of all gross remuneration, before any deduction.

👉 Conclusion: Neither social security contributions nor IRG are deductible from the payroll used as the basis for calculating the two taxes.

2. Must the return be filed even in the absence of taxes to pay?

Yes.

Article 196 bis 4 (paragraph 2) of the CIDTA is explicit:

"The return must be filed even in the absence of taxes due."

👉 Conclusion: The declaration obligation is independent of the payment obligation.

3. Are travel expenses included in the payroll?

No.

Travel expenses do not constitute a component of remuneration, but a management cost recorded in the accounts, notably under account 625 – travel, missions and entertainment, in accordance with the chart of accounts (order of 26 July 2008).

Their possible mention on the payslip is purely practical and does not give them any wage character.

👉 Conclusion: Travel expenses are excluded from the payroll.

4. Can the apprenticeship rate be offset by the continuing training rate (and vice versa)?

In one direction only.

Article 196 bis 3 (last paragraph) of the CIDTA allows only the apprenticeship rate to be topped up by any surplus from continuing vocational training when the 1% threshold is not reached for apprenticeship.

No text provides for the reverse offset.

👉 Conclusion: The offset is possible only from the continuing training rate toward the apprenticeship rate, never the reverse.

5. Is the apprenticeship tax due when the workforce is fewer than 20 employees?

Yes.

The exemption provided for in article 196 bis 1 of the CIDTA concerns exclusively the continuing vocational training tax, and only for employers with fewer than 20 employees.

No similar exemption is provided for the apprenticeship tax.

👉 Conclusion: Even with fewer than 20 employees, the apprenticeship tax remains due.

6. Are taxpayers subject to the IFU exempt from these taxes?

No.

The texts provide for no exclusion of taxpayers under the IFU regime. Article 196 bis of the CIDTA subjects to these taxes all employers established or operating in Algeria, with the sole exception of public administrations and institutions.

👉 Conclusion: The tax regime (IFU or actual) has no bearing on liability for the two taxes.

7. Who must file a "nil" return?

In principle, any entity with the status of "employer" is required to file a return, even in the absence of payment.

However, a combined analysis of the texts leads to distinguishing several situations:

• Employers who have reached the 1% rate: mandatory return with a "nil" notation.
• Persons with no employees: not concerned (no employer status).
• Employers with 1 to 19 employees and no training carried out: legally not required, but practical recommendation to file a "nil" return in order to avoid any risk of penalty.
• Employers who have not taken on any apprentices when they are required to do so: mandatory return and payment of the apprenticeship tax.

👉 Practical conclusion: In case of doubt, filing a return remains the safest option.

8. What date should be used for the number of employees declared?

No text specifies a precise reference date (31/12, annual average, maximum workforce, etc.).

Historically, companies have often used end-of-semester headcounts, a practice accepted by vocational training directorates.

The texts relating to continuing training only take permanent workers into account, while those relating to apprenticeship do not distinguish between permanent and temporary staff, creating a practical difficulty.

👉 Recommendation: Retain the method historically validated by the administration before 2022, so as to be able to invoke the principle of administrative continuity in the event of a dispute.

9. What elements are included in the payroll?

a) Accrued charges (not yet paid)

Bonuses and allowances not yet paid (accrued leave pay, annual bonuses provisioned, etc.) are excluded from the payroll.

b) Included salaries

In the absence of any legal exclusion, the following are included:

• Fixed-term contract salaries
• Executive salaries
• Apprentice salaries
• All bonuses and allowances paid, whether or not subject to IRG or social contributions

The texts refer to "all gross remuneration paid", wording confirmed by the interministerial order and the DGI circular no. 19 of 14 February 2023, which specifies:

"all bonuses and allowances."

👉 Conclusion: Everything that is paid and constitutes remuneration is included in the payroll, except for travel expenses.

10. Which month should be selected on the JIBAYATIC platform?

In accordance with article 196-6 of the CIDTA, the return must be filed before 20 February of the following year.

⚠️ Note: As of 2026, the return becomes semi-annual (Finance Law 2026).

General Conclusion

The continuing vocational training tax and apprenticeship tax are based on a clear legal logic: broad base, strict declaration obligation and limited exemptions expressly provided for by law.

Any extensive or restrictive interpretation not based on an explicit text exposes the employer to unnecessary fiscal risk. In terms of compliance, filing conservatively remains the best protection.