Cameroon Cross-Border Tax Guide 2026

Overview — Cross-Border Taxation in Cameroon

Cameroon's cross-border tax rules are governed by the General Tax Code, the OHADA Uniform Act, and various double tax treaties. The Direction Générale des Impôts (DGI) has been strengthening its international tax capacity, including participation in the OECD's BEPS Inclusive Framework. Multinational enterprises operating in Cameroon must comply with transfer pricing documentation requirements, thin capitalisation rules, and withholding tax obligations. Non-residents earning Cameroon-source income are generally subject to withholding taxes at statutory rates, which may be reduced under applicable treaties.

Transfer Pricing — OECD Guidelines

Cameroon's transfer pricing rules follow OECD guidelines. Transactions between related parties must be priced at arm's length. Documentation requirements include a master file and local file for large taxpayers. Acceptable methods include CUP, Cost Plus, Resale Price, TNMM, and Profit Split. Advance Pricing Agreements (APAs) are available. Penalties for non-compliance range from 10% to 50% of the tax adjustment plus interest.

Thin Capitalisation

Cameroon's thin capitalisation rules limit interest deductions on related-party debt. The maximum allowable debt-to-equity ratio is 1.5:1. Interest on debt exceeding this ratio is disallowed as a deduction and may be recharacterised as dividends for withholding tax purposes. The rules apply to loans from foreign parent companies, sister companies, and guaranteed third-party debt.

Withholding Taxes to Non-Residents

Payments to non-residents are subject to withholding tax at the following standard rates (treaty rates may apply):

• Dividends — 15% (reduced to 10–13% under some DTTs)
• Interest — 13% (reduced under DTTs)
• Royalties — 15% (reduced to 10% under some DTTs)
• Management fees — 15%
• Branch profits remittance — 10%

Double Tax Treaties

Cameroon has double tax treaties with France, Germany, the UK, Canada, Italy, and several other countries. Treaty benefits include reduced withholding tax rates and exemption from CGT in certain circumstances. To claim treaty benefits, the non-resident must provide a Certificate of Tax Residency and submit a treaty relief application to the DGI.

FAQs

Do I need to register for tax in Cameroon as a non-resident investor?

Non-residents earning Cameroon-source income subject to final withholding tax generally do not need to register. However, a non-resident with a permanent establishment must register and file corporate tax returns.

Does Cameroon have a General Anti-Avoidance Rule (GAAR)?

Yes, the General Tax Code includes anti-avoidance provisions allowing the DGI to recharacterise transactions for tax avoidance purposes.

How do I claim a refund of excess WHT as a non-resident?

A non-resident may claim a refund if WHT was deducted at a higher rate than the applicable treaty rate, by filing a refund claim with the DGI with supporting documents.

Disclaimer

This guide provides general information about Cameroonian cross-border taxation for the 2026 tax year. Tax laws and treaty provisions may change. Always consult with a qualified Cameroonian international tax advisor or the Direction Générale des Impôts for advice specific to your situation. InvestmentKit does not provide tax advice.