Cameroon Tax Regime

Cameroon operates a classical corporate income tax system within the Economic and Monetary Community of Central Africa (CEMAC) framework, which harmonises VAT, excise and a share of customs policy across member states while leaving the core corporate income tax rate to national law. Corporate income tax is levied at 33% for companies with annual turnover above XAF 3 billion, and at a reduced 27.5% rate for smaller companies meeting statutory criteria, with turnover-based minimum tax and advance-payment mechanisms operating as a floor and cash-flow accelerator across most taxpayer categories. The regime is set out primarily in the General Tax Code (Code Général des Impôts) as amended by annual finance laws, applies the OHADA uniform acts on company law and accounting (SYSCOHADA/SYSCOHADA révisé), and layers a distinctive 10% Additional Council Tax surcharge onto several major taxes. Cameroon remains the largest economy in the CEMAC zone and continues to promote investment in hydrocarbons, mining, agro-industry and infrastructure through a general private investment incentive regime and sector-specific fiscal regimes.

1.1 Sources

Primary legislation includes the General Tax Code (Code Général des Impôts), the CEMAC directives on VAT and excise harmonisation, the OHADA Uniform Act on Commercial Companies and Economic Interest Groups, the Investment Incentive Law (loi portant incitations à l'investissement privé) and annual finance laws (lois de finances).

1.2 Recent developments

Recent finance laws have refined the boundaries between Cameroon's flat-rate, simplified and actual-earnings taxation systems, mandated automatic inclusion in the actual-earnings system for new companies in the oil, mining, gas, credit, microfinance, insurance and mobile-phone sectors regardless of turnover, and extended the 10% Additional Council Tax surcharge — from the 2025 finance law — to excise duties, the special income tax and registration fees on public contracts, in addition to its long-standing application to corporate income tax, personal income tax, dividend withholding and VAT. The tax administration (Direction Générale des Impôts, DGI) has continued to expand mandatory electronic filing and payment, and transfer pricing documentation and audit scrutiny of related-party transactions have intensified for groups operating in the extractive and telecommunications sectors. Cameroon has not yet legislated Pillar Two, although regional CEMAC discussion of the global minimum tax continues. The most consequential change for 2026 is the taxation of non-resident digital businesses. Law No. 2025/012 of 17 December 2025, the finance law for 2026, inserted Articles 5 ter, 7 bis, 17 quater and 23 bis into the General Tax Code and added a fourth limb to Article 5 bis, so that a non-resident enterprise with a significant economic presence (présence économique significative) in Cameroon is treated as carrying on business there. That presence — which the statute calls a digital permanent establishment — arises where, in a financial year, either the gross fees invoiced for digital services supplied to customers or users located in Cameroon exceed XAF 50,000,000, or the number of users, customers or account holders located in Cameroon exceeds 1,000. The two tests are alternatives, and location is established from technical indicators such as IP address, geolocation and SIM country code, or from commercial ones such as the billing address or Cameroonian bank details. Digital services are defined non-exhaustively and reach on-demand content, online advertising and data monetisation, marketplace intermediation commissions, cloud and software-as-a-service supplies, and any other service rendered or facilitated through an electronic network or application. Corporate income tax is charged at 3% of total gross Cameroon-source revenue; that amount is the minimum assessment and, in the default regime, final and discharging, and with the 10% Additional Council Tax surcharge the effective charge is 3.3% of gross revenue. A non-resident may instead elect to be taxed at the ordinary 30% rate on a base fixed at 10% of gross Cameroon revenue — arithmetically the same 3% — but the election must be notified in writing before the start of the financial year, binds for five financial years, requires full transfer pricing documentation, and can never reduce the tax below 3% of gross revenue. The non-resident registers, files a monthly return of gross Cameroon turnover and pays by the 15th of the following month through a dedicated secure DGI portal, failing which the Article 149 quater sanctions apply, including suspension of access to the platform from Cameroonian territory. The DGI circular of 2 March 2026 applies the measure to transactions carried out from 1 January 2026 and allowed the first-year election to be made up to 15 March 2026. The charge is a direct tax on income and is separate from the VAT obligations that electronic-commerce platforms already bear.

Headline statutory corporate income tax rate for a resident company. Where sub-national (state, provincial, cantonal or municipal) corporate taxes apply, the combined rate reported by the OECD is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

Top marginal statutory personal income tax rate on employment income for a resident individual. Where sub-national (state, provincial, cantonal or municipal) income taxes are a standard part of the system, the combined top rate is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

2.1 Rates and residence

Resident corporations — including companies headquartered in Cameroon, companies with an effective place of management in Cameroon, companies with a permanent establishment or a dependent representative in Cameroon, and undertakings carrying out a full commercial cycle in Cameroon — are subject to corporate income tax (CIT) on profits earned by entities located in Cameroon; non-resident corporations are taxed only on Cameroon-source income attributable to a Cameroonian permanent establishment. The total CIT rate is 33% for companies with annual turnover above XAF 3 billion, and 27.5% for companies with turnover below that threshold that meet additional statutory criteria. Certain entities — including new companies in the oil, mining, gas, credit, microfinance, insurance and mobile-phone sectors, taxpayers approved under a tax incentive scheme, and public notaries — are automatically subject to the actual-earnings taxation system regardless of turnover. Net taxable profit is established after deduction of charges directly connected with the exercise of activities assessable in Cameroon.

Corporate bodies are classified into a flat-rate system (sole proprietorships below XAF 10 million turnover, with sector exclusions), a simplified system (turnover from XAF 10 million to below XAF 50 million), an actual-earnings system (turnover of XAF 50 million or above, or automatic inclusion as above), a non-profit organisations system, and a non-professional taxpayer system for individuals with purely passive income. A minimum tax of 2.2% or 5.5% of turnover applies depending on the taxpayer's regime, acting as an instalment of CIT that becomes the sole tax payable where it exceeds the CIT otherwise computed; advance-payment rates of 5.5%, 10%, 15% or 20% apply in specified circumstances, including higher rates for unregistered taxpayers, certain forestry companies, and in-bond goods dealers.

2.2 Dividends and participation

Dividends distributed between qualifying related Cameroonian companies can benefit from relief reducing cascading taxation within corporate groups, subject to minimum shareholding conditions under the General Tax Code. Dividends paid to non-resident shareholders are subject to withholding tax at source, with the domestic rate itself subject to the 10% Additional Council Tax surcharge described in section 2.1, and to reduction under applicable double tax treaties. Capital gains on the disposal of shares are, in principle, included in ordinary taxable profits at the standard CIT rate, subject to specific rules for gains realised on the disposal of mining and petroleum titles.

2.3 Income determination and deductions

Taxable profit is computed from accounts prepared under the SYSCOHADA (OHADA uniform accounting) framework, adjusted for tax purposes. Ordinary and necessary business expenses connected with Cameroonian activity are deductible provided they are properly documented; management fees, royalties and interest paid to foreign affiliates are subject to specific deductibility caps and documentation requirements, and payments to entities established in non-cooperative or low-tax jurisdictions face enhanced scrutiny and potential non-deductibility. Depreciation generally follows straight-line rates by asset category set out in administrative practice, with accelerated depreciation available for specified categories of industrial equipment used in priority sectors. Provisions are deductible only where specific, probable and adequately evidenced, consistent with OHADA accounting principles.

2.4 Interest limitation

Interest paid to related-party shareholders is deductible only within limits calculated by reference to a benchmark interest rate (typically linked to the regional central bank's key rate plus a margin) and subject to thin-capitalisation-style tests limiting related-party debt relative to share capital; interest exceeding these limits is disallowed. Interest paid to non-resident related lenders is additionally subject to withholding tax (as increased by the Additional Council Tax surcharge), so payer-side deductibility and payee-side withholding must both be assessed together for cross-border related-party financing.

2.5 Losses

Ordinary trading losses may generally be carried forward for a limited number of years (typically up to four years) against future taxable profits; the portion of a loss attributable to deferred tax depreciation may be carried forward without time limit. There is no loss carryback. Loss carryforwards can be jeopardised where there is a substantial change in the company's activity or corporate form.

2.6 Groups

Cameroon does not operate a comprehensive fiscal consolidation or group-relief regime; each company is generally taxed on a stand-alone basis under the actual-earnings, simplified or flat-rate system applicable to it. Corporate groups instead rely on the dividend relief described in section 2.2, on careful transfer pricing compliance for intra-group transactions, and on financing structures sized within the interest-deductibility limits in section 2.4 to manage the group's overall Cameroonian tax position.

2.7 Controlled foreign companies

Cameroon does not operate a dedicated CFC regime attributing the undistributed income of foreign subsidiaries to Cameroonian parent companies on an accruals basis. Exposure in respect of offshore low-tax structures instead arises principally through transfer pricing adjustments on related-party dealings, the disallowance of payments to non-cooperative jurisdictions described in section 2.3, and general anti-abuse scrutiny applied by the tax administration to arrangements lacking economic substance.

2.8 Transfer pricing

Related-party transactions must be conducted on arm's-length terms, and the tax administration may reassess profits where pricing between related Cameroonian and foreign entities departs from what independent parties would have agreed. Companies within qualifying groups above statutory turnover or asset thresholds must maintain transfer pricing documentation capable of demonstrating the arm's-length nature of related-party dealings, and country-by-country reporting obligations apply to Cameroon-parented multinational groups above the applicable consolidated revenue threshold, consistent with the OECD BEPS Action 13 minimum standard. Audit focus on transfer pricing has increased in recent years, particularly for the extractive and telecommunications sectors.

2.9 Incentives

The private investment incentive regime grants time-limited exemptions or reductions of corporate income tax, minimum tax, registration duties, employer payroll contributions and import duties for qualifying new investments during defined installation and operating phases, calibrated by investment size and sector, with enhanced benefits for priority sectors such as agro-industry, social housing, tourism and value-added manufacturing. Sector-specific fiscal regimes exist for mining and petroleum activities, typically combining specific royalty and surface-rental regimes with tailored corporate tax rules set out in the Mining Code and petroleum production-sharing or concession arrangements. Approved investors under the incentive regime are automatically placed in the actual-earnings taxation system described in section 2.1.

2.10 Pillar Two

Cameroon has not yet enacted Pillar Two legislation implementing a domestic minimum top-up tax, an income inclusion rule or an undertaxed profits rule. Cameroonian constituent entities of in-scope multinational groups may nonetheless be affected indirectly where a foreign parent jurisdiction applies an income inclusion rule or undertaxed profits rule to top up low-taxed Cameroonian profits, particularly where investment incentives reduce the effective rate below the 15% global minimum; monitoring of CEMAC-level and broader regional developments on this front is ongoing.

2.11 Branch income and reorganisations

A branch (permanent establishment) of a foreign company is taxed on Cameroon-source profits at the same 33%/27.5% rate applicable to resident companies, determined under rules analogous to those applied to a locally incorporated subsidiary. Cameroon does impose a branch-level charge in addition to corporate income tax, and it is a statutory deeming rule rather than an administrative interpretation. Under the closing paragraph of section 36 of the General Tax Code, and subject to international conventions, the profits of companies whose location or head office is not in Cameroon are deemed to be distributed in each fiscal year to persons not resident or not having their registered office in Cameroon, so a branch's profits fall into the tax on income from movable capital whether or not they are actually remitted to head office. That charge is levied at the flat 15% rate in section 70(1), increased by 10% additional council tax under section 71, giving an effective 16.5%, or 30% before the council uplift where the recipient is resident or established in a territory or State treated as a tax haven within the meaning of section 8c. Treaty relief is available where a double tax treaty applies, so groups should model an effective Cameroon burden on branch structures materially above the headline corporate rate and compare it against a locally incorporated subsidiary. Domestic mergers, demergers and similar reorganisations carried out under the OHADA Uniform Act on Commercial Companies can, subject to conditions and often prior administrative agreement, benefit from deferral of taxation on latent gains and continuity of tax attributes, though relief is narrower and less automatic than under OECD-style reorganisation regimes.

3.1 Residence and rates

Individuals resident in Cameroon (by reason of home, habitual place of residence, or centre of economic interests) are taxed on worldwide income; non-residents are taxed on Cameroon-source income only. Personal income tax (impôt sur le revenu des personnes physiques, IRPP) applies progressive rates by income category — salaries, business profits, non-commercial profits, property income and investment income — with the top marginal bracket reaching approximately 35% on the highest tranche of taxable income before the 10% Additional Council Tax surcharge is layered on top of the computed liability. A schedular special tax on income (impôt sur le revenu des capitaux mobiliers and related regimes) applies to specific categories of investment income at flat rates.

3.2 Capital income and real estate

Dividends and interest paid to resident individuals are generally subject to withholding tax on income from stock and shares, itself subject to the 10% Additional Council Tax surcharge, discharging or crediting against the individual's overall liability depending on the nature of the income. Capital gains realised by individuals outside a business activity are taxed under asset-specific rules, with gains on real estate and on shares in Cameroonian companies subject to registration-duty-linked or schedular treatment rather than a single unified capital gains tax. Rental income is taxed under the property income category of the IRPP at progressive rates after standard deductions for expenses and depreciation-equivalent allowances.

3.3 Social security and payroll

Employers and employees contribute to the National Social Insurance Fund (Caisse Nationale de Prévoyance Sociale, CNPS) covering family benefits, work-accident insurance, and retirement pensions, with the employer bearing the larger share of combined contributions as a percentage of gross salary, subject to periodically revised contribution ceilings. Employers withhold IRPP on salaries monthly and remit it together with CNPS contributions and other payroll-related levies (including the Additional Council Tax surcharge on PIT withheld) to the tax administration and CNPS respectively.

3.4 Inbound individuals

Cameroon does not levy a net wealth tax. There is no comprehensive inheritance or gift tax code comparable to European regimes, though registration duties apply to the transfer of certain assets, including real estate, on death or by gift, at rates that vary with the relationship between the parties and the nature of the asset. Expatriate employees become subject to the same schedular IRPP rules as residents once Cameroonian tax residence is established, with relief from double taxation available under Cameroon's limited treaty network and, within the CEMAC zone, under regional coordination arrangements.

Domestic withholding applies to dividends paid to non-residents, interest paid to non-residents, and royalties and technical or management service fees paid to non-residents, with the underlying statutory rates further increased by the 10% Additional Council Tax surcharge described in section 2.1, subject to reduction under Cameroon's double tax treaties. Payments to non-cooperative or low-tax jurisdictions can attract enhanced withholding rates or denial of deductibility at the payer level in addition to withholding at the payee level. Cameroon's treaty network is comparatively limited, including conventions with France and other CEMAC and African partner states, together with a small number of other treaty partners, and treaty relief generally requires residence certification together with satisfaction of beneficial-ownership and anti-abuse conditions. Withholding of the special income tax by Cameroonian payers continues to apply to payments made to non-resident digital businesses within the significant-economic-presence regime described in section 1.2, and the DGI circular of 2 March 2026 treats the tax so withheld as a credit against the corporate income tax due for the same financial year. Neither that regime nor the circular contains a reservation for double tax treaties, in contrast with Article 5 quater of the General Tax Code on airlines and shipping and Article 225 on the special income tax, each of which opens with an express reservation for international tax conventions.

Relief at source is generally more limited than under EU-style directive systems; non-resident recipients typically bear withholding at the statutory (Council-Tax-inclusive) or treaty rate directly, with excess withholding recoverable, where applicable, through treaty-based refund claims filed with the DGI. Groups should confirm which withholding rate and Council Tax treatment applies to a given payment type before executing cross-border intra-group transactions, since services, royalties, interest and dividends attract materially different documentation and reporting requirements.

5.1 General anti-abuse and hybrids

The General Tax Code contains general anti-abuse provisions empowering the tax administration to disregard or requalify transactions and legal structures whose principal purpose is to obtain a tax advantage inconsistent with the object of the legislation, complemented by specific rules disallowing or capping deductions for payments to non-cooperative or low-tax jurisdictions. There is no comprehensive statutory regime targeting hybrid mismatches equivalent to the EU ATAD hybrid rules; instead, mismatches are principally addressed through the ordinary deductibility conditions in sections 2.3–2.4, transfer pricing adjustments, and the general anti-abuse rule applied case by case.

5.2 Exchange of information and disclosure

Cameroon participates in international exchange-of-information arrangements, including under its double tax treaties and regional CEMAC cooperation mechanisms, and country-by-country reporting applies to in-scope multinational groups as described in section 2.8. There is no domestic mandatory disclosure regime for cross-border tax arrangements comparable to the EU's DAC6. Treaty benefits are subject to beneficial-ownership requirements and increasing administrative scrutiny of substance in intermediate holding structures, particularly for dividend, interest and royalty flows routed through low-tax jurisdictions and for extractive-sector arrangements.

6.1 VAT

VAT is levied at a standard rate of 19.25% (a 17.5% base rate plus the 10% Additional Council Tax surcharge applied to the base VAT rate), applicable to most supplies of goods and services in Cameroon and to imports. The 2026 finance law added a reduced base rate of 10% (rewriting section 142 of the General Tax Code) for interest on mortgage loans taken out by individuals acquiring a first social-housing home, sales of social housing to such individuals, and lettings of social housing by public property developers — supplies that were previously exempt. Specific exemptions remain for certain essential goods and financial services, and exports are zero-rated. Registration and the applicable filing regime depend on the taxpayer's turnover-based taxation system described in section 2.1. VAT returns and payments are due monthly, filed electronically through the DGI's platform for taxpayers within the large- and medium-enterprise tax centres. Input VAT is recoverable against output VAT for taxable activities, subject to documentation requirements and exclusion rules for certain categories of expenditure.

6.2 Transaction, payroll and other taxes

Registration duties apply to the transfer of real estate, business assets (fonds de commerce) and shares in Cameroonian companies, at rates that vary by asset type and transaction structure, with registration fees for public contracts now also subject to the Additional Council Tax surcharge under the 2025 finance law. A payroll-based employer contribution funds vocational training programmes, in addition to CNPS social security contributions described in section 3.3. A specific business licence tax (patente) is levied on companies and self-employed persons carrying on a commercial, industrial or professional activity, calculated by reference to turnover and sector-specific criteria, and is payable annually to the local authority in which the business operates. Excise duties — themselves subject to the Additional Council Tax surcharge since the 2025 finance law — apply to tobacco, alcohol, petroleum products and certain luxury goods, and a special income tax (SIT, also surcharged) applies to specified categories of payments to non-residents for services.

7.1 Filing, assessment and audit

The tax year is generally the calendar year. Corporate income tax returns, together with statutory financial statements prepared under SYSCOHADA, are due within a defined period after the close of the accounting year (commonly around three to four months), with monthly minimum-tax instalments during the year credited against the final CIT liability and a balancing payment on filing. The DGI administers direct and indirect taxes through specialised units for large enterprises, medium enterprises and individuals (Centres des Impôts), and conducts risk-based audits of filed returns, transfer pricing positions and VAT credits, with statutory reassessment periods generally extending several years from the filing deadline.

7.2 Rulings, appeals and penalties

Taxpayers may request administrative guidance on the tax treatment of specific transactions from the DGI, though formal binding-ruling practice is less developed than in mature OECD jurisdictions. Disputed assessments can be challenged first through an administrative claim to the tax administration and, if unresolved, before the competent administrative courts. Late filing and late payment attract statutory penalties and interest, with more severe penalties for fraud or deliberate concealment; voluntary regularisation before the start of an audit generally attracts reduced penalties compared with amounts identified during a controlled examination.

Where the minimum tax exceeds the ordinary CIT liability computed on profits, the minimum tax becomes the sole tax payable, and is reconciled at the time of filing the annual return. Taxpayers benefiting from private investment incentive exemptions must continue to file returns during exempt periods to preserve their entitlement and to allow the administration to verify continued compliance with the conditions of the incentive granted.

9.1 Entity choice

The société à responsabilité limitée (SARL) is the most common vehicle for small and medium enterprises, with a société anonyme (SA) typically used for larger operations, regulated capital-market activity, or where a board structure is required by sector regulation (such as banking, insurance and telecommunications). Both are governed by the OHADA Uniform Act on Commercial Companies, giving a common company-law framework across CEMAC and wider OHADA member states. Branches of foreign companies are a viable alternative for time-limited projects, particularly in the extractive sector, but face specific registration and, in some cases, conversion requirements after an extended period of operation. Partnerships and economic interest groupings (groupements d'intérêt économique) are used for joint ventures and cost-sharing arrangements, notably in petroleum consortia.

9.2 Structuring and incentives

Investors should evaluate eligibility for the private investment incentive regime or sector-specific (mining, petroleum, agro-industrial) fiscal regimes at the structuring stage, since approval is generally required in advance of the qualifying investment being made, and automatically places the investor in the actual-earnings taxation system. Holding structures can make use of the dividend relief described in section 2.2, while related-party financing must be sized within the benchmark-interest-rate and thin-capitalisation-style constraints in section 2.4 to preserve full interest deductibility. Groups with material related-party dealings should prepare transfer pricing documentation proactively given the administration's increasing audit focus on cross-border pricing, particularly in the extractive and telecommunications sectors, and should map the Additional Council Tax surcharge across every affected tax line when modelling cash flows.

9.3 Worked effective-rate illustration

A Cameroonian SARL with turnover above XAF 3 billion earns EBITDA of XAF 2,000,000,000, books depreciation of XAF 300,000,000 and deductible net interest of XAF 150,000,000 (within the benchmark-rate and thin-capitalisation limits). Taxable profit is 2,000,000,000 − 300,000,000 − 150,000,000 = XAF 1,550,000,000. CIT at the standard 33% rate is XAF 511,500,000. Turnover for the year is XAF 6,000,000,000, so the 2.2% minimum tax instalment would be XAF 132,000,000 — below the computed ordinary CIT, so the minimum tax operates only as a creditable instalment and the company's final liability is the ordinary CIT of XAF 511,500,000, an effective rate of 511,500,000 / 1,550,000,000 = 33.0% on taxable profit, consistent with the statutory rate. If the after-tax profit of XAF 1,038,500,000 were fully distributed to a non-resident parent outside a qualifying relief, dividend withholding at the domestic rate of 16.5% (inclusive of the 10% Additional Council Tax surcharge) of XAF 171,352,500 would apply, giving a combined headline burden on distributed profits of roughly 33% + (67% × 16.5%) ≈ 44.1% before treaty relief.

9.4 Compliance

Expect electronic filing for CIT, VAT and payroll obligations through the DGI's online platform for larger taxpayers, annual financial statements prepared under the SYSCOHADA accounting framework and filed with the commercial registry (Registre du Commerce et du Crédit Mobilier), transfer pricing documentation maintained contemporaneously for groups above the applicable thresholds, and registration formalities on real estate, business-asset and share transfers. Companies benefiting from private investment incentive or sectoral regimes must maintain the records needed to demonstrate continued compliance with the conditions of their approval, since incentives can be withdrawn or clawed back if conditions are breached.