The Tunisian Medical Council has expressed reservations about implementing e-invoicing in the medical profession without considering its unique aspects. In a statement, the council stated that the medical profession operates within a regulated sector subject to multiple declaration, control, and data intersection mechanisms. The council emphasized that e-invoicing cannot be applied to the medical profession without taking into account its specificities, such as fee notes, professional secrecy, and protection of patients' personal and medical data.
The council noted that professional secrecy is a fundamental commitment imposed on every doctor. It stressed that updating the tax system should be gradual, clear, and in line with the law, without compromising the specifics of the medical profession or professional secrecy. The council also emphasized that the medical profession is a free profession and a regulated sector, subject to a specific legal, regulatory, and ethical framework, and is committed to respecting the law and its tax obligations.
According to the council, since the issuance of judgments related to the extension of e-invoicing to service provision, the medical profession has not been automatically considered subject to this procedure. This is due to its classification as a non-commercial profession, governed by a specific system based on fee notes. The council stated that the law on professional ethics stipulates that the practice of medicine should not be commercial in nature.
However, the issuance of a general memorandum in 2026, explaining the provisions of Article 53 of the 2026 Finance Law and expanding the scope of e-invoicing, has changed the situation. The council believes that this memorandum has exceeded its interpretive role and expanded the text's interpretation, leading to the inclusion of non-commercial professions, despite not being explicitly mentioned in the article.
The council is seeking a legislative amendment and the provision of necessary legal and technical guarantees before implementing e-invoicing in the medical profession. It emphasized that the specifics of the medical profession must be taken into account, including fee notes, professional secrecy, and protection of patients' personal and medical data.
The council's statement highlights the need for a nuanced approach to implementing e-invoicing in the medical profession. It also underscores the importance of balancing the need for tax compliance with the unique aspects of the medical profession. The council's concerns are likely to spark further debate about the implementation of e-invoicing in Tunisia.
The Tunisian government has not yet responded to the council's concerns. However, the council's statement is likely to influence the government's approach to implementing e-invoicing in the medical profession. The issue is expected to be closely watched by medical professionals, policymakers, and other stakeholders in Tunisia.
Key points
- The Tunisian Medical Council has expressed concerns over implementing e-invoicing in the medical profession without considering its unique aspects.
