Cameroon: Global Tax Guide

Legislation

General Tax Code (2024)
2025 Finance Law

Residence/Territorial Scope

Article 5 of the General Tax Code provides that the profits liable to corporation tax are determined by taking into account only the profits from operations carried out in Cameroon, subject to the provisions of double tax treaties.

Article 5 bis provides that the following are deemed to be operated in Cameroon:

• companies whose registered office or place of effective management is located in Cameroon;
• companies that have a permanent establishment in Cameroon;
• companies that have a dependent representative in Cameroon.

Profits are also taxable in Cameroon if an entity carries out carry out activities forming a complete commercial cycle in Cameroon.

Entities Within Scope

Article 3 of the General Tax Code provides that the following are liable to corporation tax:

• Joint stock companies, de facto partnerships, cooperative societies and public establishments or bodies:
• public limited companies, limited liability companies, de facto companies, cooperative companies and their unions;
• public establishments, State bodies enjoying financial autonomy and all other legal persons engaged in profit-making operations or operations.
• Civil societies
• Civil partnerships whose members include one or more capital companies or which have opted for this tax regime;
• Civil partnerships that have opted for corporate income tax under the conditions set for partnerships.
• Partnerships that have opted for corporate income tax
• Microfinance institutions regardless of their legal form and nature.

Corporate Income Tax Rates

Article 17 of the General Tax Code provides that the rate of corporation tax is 30%. This is increased by 10% for the additional municipal tax (ie a total 33% tax rate).

Taxable profit less than 1,000 CFA francs is disregarded.

Article 17 bis of the General Tax Code provides that the rate of corporation tax for taxpayers with a turnover equal to or less than 3 billion CFA francs is set at 25%.

Minimum Tax

Article 21 of the General Tax Code provides that for persons subject to the actual tax regime, an advance payment representing 2.2% of the turnover achieved during each month is paid no later than the 15th of the following month.

For production companies in specified sectors, an advance payment representing 2.2% of the turnover achieved after a 50% allowance. These are companies in the following sectors:

• flour milling sector;
• pharmaceutical sector;
• fertilizer sector.

For companies distributing products in a specified sector, an advance payment representing 15.4% of the gross margin is paid by the 15th of the following month at the latest. These are the distribution companies of:

• petroleum products and domestic gas;
• products of flour milling;
• pharmaceuticals;
• press products;
• fertilizer.

Taxpayers in these sectors may, however, opt for the ordinary law regime when it is more favourable to them.

In this case, the advance payment is calculated at the rate of 2.2% applied to turnover. The option is irrevocable until the end of the financial year.

For persons subject to the simplified regime, an advance payment representing 5.5% of the turnover achieved during each month, and paid by the 15th of the following month at the latest. This is increased to 14.4% (in Finance Law 2025) for companies distributing products in a specified sector (see above).

Reduced Rates

Article 108 of the General Tax Code provides that companies that admit their ordinary shares to the Central African Stock Exchange benefit from the application of the following reduced corporate tax rates:

• a reduced corporate tax rate of 25%;
• a reduced rate of 1.5% of the advance payment and the minimum collection of Corporate Tax.

Under Article 109 of the General Tax Code, companies that issue securities on the bond market of the Stock Exchange Central African Mobiliars benefit from the application of a reduced corporate tax rate of 25%.

Taxable Income and Allowances

Article 6 of the General Tax Code provides that taxable profit is the net profit determined on the basis of the overall results of operations of all kinds carried out by companies during the period used as a basis for the tax, including in particular the disposal of any element of the assets either in progress or at the end of their operation.

Net profit is made up of the difference between the values of the net assets at the end and at the beginning of the period the results of which are to be used as a basis for tax, less additional contributions and increased by the deductions made during this period by the partners. Net assets are defined as the excess of asset values over the total liabilities of third-party receivables, depreciation and justified provisions.

Inventories are measured at the actual cost of acquiring or producing the asset. If the inventory value is less than the input value, the impairment is recognized through the inventory impairment provision. Work in progress is valued at actual cost.

Deductions

Article 7 of the General Tax Code provides that the net taxable profit is established after deduction of all expenses directly necessary for the exercise of the taxable activity in Cameroon. This includes, overhead costs, rental expenses, insurance premiums, finance expenses, depreciation.

There are some specific limitations including:

• The general expenses of the head office for the part related to operations carried out in Cameroon and the remuneration of certain effective services (studies, technical, financial or accounting assistance) rendered to Cameroonian companies by foreign or Cameroonian natural or legal persons is deductible up to 2.5% of the taxable profit before deduction of the expenses in question.

• Commissions or brokerage on goods purchased on behalf of companies located in Cameroon, up to a limit of 5% of the turnover of purchases.

• The sums paid for the use of valid patents, trademarks, designs and models up to an overall limit of 2.5% of taxable profit before deduction of the expenses involved. This limitation does not apply to sums paid to companies that do not participate directly or indirectly in the management or capital of a Cameroonian company.

• Gifts, donations and subsidies are generally not deductible, however, payments to research and development bodies and to works or bodies of general interest of a philanthropic, educational, sporting, scientific, social and family nature, provided that they are located in Cameroon, are allowed as a deduction as long as they are justified and within the limit of 0.5% of the turnover for the financial year.

• Donations and subsidies allocated to clubs participating in official national elite competitions, or to approved bodies in charge of organising official sports competitions, are allowed as a deduction as long as they are justified and within the limit of 5% of the turnover for the financial year.

Depreciation is deductible based on the probable useful life as shown by the standards imposed by each type of operation, including those which would have been previously deferred in a period of loss, but the rates may not be higher than those set out in the General Tax Code.

Provisions made to meet clearly specified losses or expenses that are likely to occur due to current events, are deductible provided that they have actually been recorded in the entries for the financial year.

In addition to the general conditions for the deduction of provisions provided for above, provisions for doubtful accounts must:

• be constituted on receivables recorded on the assets side of the balance sheet and not covered by real guarantees;

• have given rise to the implementation of amicable or forced recovery provided for by the OHADA Uniform Act on the organization of simplified recovery procedures and enforcement procedures against the debtor.

The 2025 Finance Law provides that losses relating to bad debts of less than CFA 500,000 that have been provisioned for a minimum period of 5 years, are automatically allowed for deduction. This amount is increased to CFAF 3,000,000 for credit institutions.

Provisions for doubtful debts and liabilities of credit and microfinance institutions are not deductible when the provisions relate to cumulative annual credits of at least equal to or greater than CFA 50 million, granted to the same company, on the basis of financial statements not certified by an auditor.

Foreign exchange losses may not give rise to deductible provisions.

Article 8b of the General Tax Code provides that expenses and remuneration of any kind, accounted for by a company domiciled or established in Cameroon and related to transactions with natural or legal persons domiciled or established in a territory or a State considered to be a tax haven, are not deductible for the determination of corporate income tax.

However, purchases of goods and merchandise necessary for business acquired in their country of production and which have been subject to customs duties, as well as remuneration for the provision of services relating thereto, are deductible.

A State or territory whose corporation tax rate is less than one-third of that charged in Cameroon, or a State or territory considered to be non-cooperative in terms of transparency and exchange of information for tax purposes by the international bodies in charge of promoting transparency and the exchange of information for tax purposes is considered to be a tax haven.

Tax Losses

Article 12 of the General Tax Code provides that tax losses can be carried forward and offset against losses for future years for up to the fourth financial year following the loss-making year.

For credit institutions and companies in the State’s portfolio undergoing restructuring, losses can be carried forward until the end of the sixth year following the financial year.

Withholding Tax

Cameroon applies withholding taxes on income paid to natural persons and corporate bodies domiciled abroad by individuals or legal entities located in Cameroon.

A standard rate of 15% applies to remunerations paid abroad in respect of various services provided and used in Cameroon.

A reduced rate of 3% applies to:

• Certain remunerations under public procurement.
• Remunerations paid abroad for the provision of access to digital audio-visual services.
• Remunerations paid for all kind of services provided to oil companies during the R&D phases.
• Remunerations paid by maritime transport companies governed by Cameroonian law for the rental and chartering of ships, the rental of space of foreign ships, and for commissions paid to port agents abroad.
• Commissions paid to money transfer companies located abroad, after deduction of the share due local partners.

Dividends are subject to a total withholding tax rate of 16.5% applies when paid to Cameroon residents and non-residents (increased to 33% of the recipient is resident in a tax haven).

Interest from foreign loans is subject to 16.5% withholding tax (increased to 33% of the recipient is resident in a tax haven).

Royalties paid to non-residents are subject to a 15% withholding tax.

Transfer Pricing

Article 19 of the General Tax Code provides for the arms length basis and states that where an entity is dependent on or has control of enterprises situated in Cameroon or outside Cameroon any profits indirectly transferred to the latter either by way of an increase or decrease in the purchase or sale prices, or by any other means, shall be incorporated into the results of the Cameroon entity for corporation tax purposes.

The condition of dependency or control isn’t required where the transfer of profits is made to undertakings which are:

• either established or resident in a State or territory considered to be a tax haven; or

• subject to a preferential tax regime (defined as a company not subject to tax in its country of residence or whose corporation tax rate is less than half the tax rate in Cameroon).

Article 19 bis of the General Tax Code states that a relationships of dependency or control shall be deemed to exist between two undertakings:

• where one of the parties holds, directly or through an intermediary, 25% of the other’s share capital or voting rights or in fact exercises decision-making power therein; or

• when they are both placed under the condition defined. above, under the control of the same company or the same person.

CFC Rules

None