Minister of Finance Yassine Jaber issued a decision setting out the details for the implementation of Article 52 of Law No. 40/2026 (the 2026 General Budget Law), concerning the imposition of an additional exceptional tax on profits realized from purchases of US dollars through the "Sayrafa" platform, specifying the mechanisms for calculating taxable profits, the obligations for declaration and payment, as well as the duties of banks and the tax administration. The decision mandates that any natural or legal person whose total purchases of US dollars via the "Sayrafa" platform during the years 2021, 2022, and 2023 exceeded the amount of 100,000 US dollars shall be subject to an additional exceptional tax of 17% on the net profits generated from those transactions, regardless of whether they are subject to income tax or not. In calculating the profits, the decision adopted the difference between the net amounts paid by the beneficiary in Lebanese pounds and the actual net value of the dollars obtained on the date of the transaction's execution, after deducting all commissions and amounts withheld by banks for executing the operations. The decision obligates commercial banks operating in Lebanon to provide the tax administration, within a two-month period from the date of its publication, with all data related to "Sayrafa" operations executed through them during the aforementioned three years, electronically and in a specific format containing detailed information about the account holders, transaction values, dates, and associated bank deductions, including joint accounts and the mechanism for distributing transactions among their owners. It also obligates persons covered by the provisions of the decision, whether they are assessed on the basis of actual profit or lump-sum profit, to submit an independent tax return according to the approved form within a two-month period from the date of the decision's publication, and to settle the due tax, under penalty of the delay fines for declaration and payment stipulated in the Tax Procedures Law. The decision affirmed that the tax administration will audit the returns and accounting records related to "Sayrafa" operations for the years 2021, 2022, and 2023, both for taxpayers who had previously declared these profits and those who had not, while reserving its right to assess retroactive taxes and fines when necessary. The decision exempted from the exceptional tax the differences resulting exclusively from dollar purchase operations related to salaries and wages carried out in accordance with Banque du Liban circulars. Conversely, the decision allowed taxpayers who had previously paid the tax under the provisions of the 2024 budget, and whose transaction value did not exceed 100,000 US dollars, to submit requests for the refund of the paid tax. It also permitted those whose transactions exceeded this threshold, and whose bank commissions and deductions were not factored in when determining profits, to recalculate the tax on the basis of net profit and submit a request for the refund of the difference. The decision stated that declarations must be submitted in paper format exclusively through the "LibanPost" company, while the tax can be paid at banks, "LibanPost", OMT, B.O.B, Whish Money, Cash Plus, or any entity subsequently approved by the Ministry of Finance. Furthermore, the decision cancelled Decision No. 647/1 issued on June 4, 2024, with the new decision entering into force immediately upon its publication in the Official Gazette and on the Ministry of Finance's website. Below is the text of the decision: Determination of the details for the implementation of Article 52 of Law No. 40 dated 10/2/2026 (The 2026 General Budget Law) The Minister of Finance, Pursuant to Decree No. 53 dated 8/2/2025 (Formation of the Government), Pursuant to Law No. 324 dated 12/2/2024 (The 2024 General Budget Law), particularly Article 93 thereof, Pursuant to Law No. 40 dated 10/2/2026 (The 2026 General Budget Law), particularly Article 52 thereof, Pursuant to Legislative Decree No. 144 dated 12/6/1959 and its amendments (Income Tax Law), particularly Articles 10, 11, 12, 14, 17, 18, 31, and 32 thereof, Pursuant to Law No. 44 dated 11/11/2008 and its amendments (Tax Procedures Law), particularly Articles 5, 8, 54, 55, and 109 thereof, Pursuant to the circulars issued by Banque du Liban concerning "Sayrafa" operations, particularly Circular No. 161 dated 16/12/2021, Pursuant to the proposal of the Director General of Finance, And after consulting the Shura Council (Opinion No. 184/2025-2026 dated 5/5/2026), Decides the following: Article One: This decision determines the details for the implementation of Article 52 of Law No. 40 dated 10/2/2026 (The 2026 General Budget Law). Article Two: In order to determine the natural or legal person addressed by Article 52 referred to in Article One of this decision, the value of all operations executed by that person on the "Sayrafa" platform based on Banque du Liban circulars, particularly Circular No. 161 dated 16/12/2021, during the years 2021, 2022, and 2023, shall be aggregated. To determine the value of these operations, the total purchases of US dollars transferred by Banque du Liban before deducting any amounts withheld by the bank shall be adopted. Any person whose total purchases of US dollars at the electronic platform rate ("Sayrafa") during those years exceeded the amount of 100,000 US dollars shall be considered covered by this tax, regardless of whether that person is subject to or exempt from income tax. The aggregate of accounts belonging to a depositor shall be treated as a single account, and every account or aggregate of accounts belonging to an estate shall be treated as a single account. The full amount used from a joint account by one of its owners shall be added to the amounts used by that person from their private accounts or from their other joint accounts. Article Three: Commercial banks operating in Lebanon through which operations were executed based on Banque du Liban circulars, particularly Circular No. 161/2021, are obligated to provide the tax administration with all information related to the "Sayrafa" operations executed through them, regardless of their value, electronically within an Excel file on a CD, within a period of two months from the date of publication of this decision, provided that this information is entered exclusively according to the table attached to this decision and in accordance with the columns specified therein. The information shall be entered into the designated fields in the aforementioned table, to include with respect to: - A natural person: full name, mother's name, date of birth, registry number and place of registration, tax ID number (if any), address, and telephone number. - A legal person: tax ID number and name as registered with the Ministry of Finance or in the Commercial Register, address, and telephone number. The information shall also include a list of operations containing: the number of operations (sequence of operations for each person), deposit date, value paid in Lebanese pounds, execution date of each operation (date of transfer from Banque du Liban), value received in US dollars, and all amounts withheld by the bank for executing the operation, detailed by currency. In the presence of a joint account, the information shall be entered independently for each account holder in accordance with the calculation mechanism stipulated in Article Two of this decision, stating the distribution percentage in the designated box. Article Four: The profit subject to the additional exceptional tax stipulated in Article 52 of Law No. 40 dated 10/2/2026 (The 2026 General Budget Law) shall be determined on the basis of the difference between the net value in Lebanese pounds paid by the person in exchange for the dollars obtained via the "Sayrafa" platform, and the actual net value of these dollars in Lebanese pounds on the date of the operation's execution, meaning after deducting all amounts withheld by the bank for executing the operation. Article Five: If the natural or legal person—whether a partnership or a capital company—covered by the provisions of Article 52 referred to above, is subject to income tax on the basis of actual profit and has either shown or not shown the profit resulting from "Sayrafa" operations executed by them in their accounting records and in their annual business results return, they are required to submit an independent return according to the attached form, within a period of two months from the date of publication of this decision, showing the profit in accordance with the provisions of Article Four of this decision, and subjecting it to the additional exceptional tax at a rate of 17%, which they shall pay using the payment notice attached to this decision. The tax paid on this profit shall not be considered a deductible expense from their revenues for the year 2026 or any other year. Anyone who fails to comply with this obligation shall be subject to a delay fine for late submission of the return as stipulated in the amended Article 109 of the Tax Procedures Law at a rate of 10% for each month of delay, taking into account the minimum and maximum limits, as well as a delay fine for late payment as stipulated in the amended Article 55 of the Tax Procedures Law at a rate of 2% for each month of delay. Article Six: If the legal person is mandatorily subject to income tax on the basis of lump-sum profit pursuant to the provisions of Article 44 of the Income Tax Law, or is a natural person subject to assessment on the basis of lump-sum profit optionally or mandatorily pursuant to the aforementioned Article 44, and has either included or not included in their annual return the revenues resulting from "Sayrafa" operations, they are required to submit an independent return according to the attached form, within a period of two months from the date of publication of this decision, showing the profit in accordance with the provisions of Article Four of this decision, and subjecting it to the additional exceptional tax at a rate of 17%, which they shall pay using the payment notice attached to this decision. Anyone who fails to comply with this obligation shall be subject to a delay fine for late submission of the return as stipulated in the amended Article 109 of the Tax Procedures Law at a rate of 10% for each month of delay, taking into account the minimum and maximum limits, as well as a delay fine for late payment as stipulated in the amended Article 55 of the Tax Procedures Law at a rate of 2% for each month of delay. Article Seven: The tax administration shall audit the business of taxpayers who have shown or not shown those revenues in their returns and records for the years 2021, 2022, and 2023, and shall assess the due taxes and fines. The tax administration shall also audit the returns submitted by the natural and legal persons mentioned in Article Two of this decision who declared values different from those received from the banks, and shall assess the due taxes and fines. The tax administration reserves its right to audit the business and returns of the remaining taxpayers based on study programs or based on other reasons established by it. Article Eight: Exempted from this additional exceptional tax are solely the differences related to salaries and wages resulting from dollar purchase operations in accordance with the circulars issued by Banque du Liban, particularly Circular No. 161/2021. Article Nine: The forms attached to this decision concerning the declaration of profits realized by natural and legal persons as a result of operations executed by them on the "Sayrafa" platform subject to the tax stipulated in Article 52 of the 2026 General Budget Law shall be adopted as follows: Form Number Form Name T5 Declaration of profits realized by natural and legal persons as a result of operations executed by them on the "Sayrafa" platform subject to the tax stipulated in Article 52 of the 2026 General Budget Law. S18 Notice of payment of tax on profits realized by natural and legal persons as a result of operations executed by them on the "Sayrafa" platform stipulated in Article 52 of the 2026 General Budget Law. Article Ten: Natural or legal persons who have previously declared and paid the tax on the profit resulting from "Sayrafa" operations pursuant to Article 93 of the 2024 General Budget Law and Decision No. 647/1 dated 4/6/2024, and whose transaction value did not exceed 100,000 US dollars, may submit a request for the refund of that tax to the financial department within whose jurisdiction their place of residence or tax assessment falls, in accordance with the provisions of Article 54 of the Tax Procedures Law. Persons whose transaction value exceeded 100,000 US dollars, and from whose profits the amounts withheld by the bank for executing the operations were not deducted, also have the right to recalculate the due tax on the basis of net profit, and to submit a request for the refund of the tax excess to the financial department within whose jurisdiction their place of residence or tax assessment falls, in accordance with the provisions of Article 54 of the Tax Procedures Law. Article Eleven: The forms approved pursuant to Article Nine of this decision shall be submitted in paper format exclusively through the Lebanese Postal Company (LibanPost). Article Twelve: The taxpayer may make payment at one of the banks or their branches, the Lebanese Postal Company (LibanPost), OMT, B.O.B, Whish Money, Transfer International S.A.L. (Cash Plus), or any other company approved by the Ministry of Finance for the payment of taxes and fees. Article Thirteen: Decision No. 647/1 dated 4/6/2024 is repealed. Article Fourteen: This decision shall be published in the Official Gazette and on the website of the Ministry of Finance and shall come into effect upon its publication in the Official Gazette.