Comoros Cross-Border Tax Guide: WHT, DTTs, Transfer Pricing 2026

Q: Can I repatriate profits from Comoros tax-free?

Dividends to non-residents: 10% WHT (treaty-reducible). Interest/royalties: 10% WHT (treaty-reducible). No branch remittance tax on PE profit repatriation.

Q: What is the procedure for claiming DTT benefits?

Provide the payer with a Treaty Relief Application, Certificate of Tax Residency, and beneficial ownership declaration. Apply treaty rate at source or claim a refund.

Comoros' cross-border tax framework features withholding taxes on outbound payments (dividends 10%, interest 10%, royalties 10%), a limited network of Double Taxation Treaties (primarily France and select francophone African countries), and transfer pricing rules aligned with francophone African standards. Here is how cross-border taxation works in 2026.

Cross-border taxation in Comoros is governed by the General Tax Code and Comoros' Double Taxation Treaties. The system is designed to facilitate international trade and investment while protecting Comoros' tax base. Withholding tax rates apply to certain payments from Comorian residents to non-residents. Transfer pricing rules ensure that transactions between related parties are conducted at arm's length. The DGI has a dedicated international tax unit for cross-border matters. Investment income tax →

Real-world example: A French company receives KMF 5,000,000 in dividends from its Comorian subsidiary. Without a treaty, WHT at 10% = KMF 500,000. Under the Comoros-France DTT, the rate may be reduced to 5% = KMF 250,000. A Chinese company licensing software to a Comorian company receives KMF 2,000,000 in royalties: domestic WHT 10% = KMF 200,000, and since Comoros has no DTT with China, no treaty reduction is available. Corporate tax overview →

Withholding Tax Rates

Dividends to non-residents: 10% (may be reduced under DTT)
Interest to non-residents: 10% (may be reduced under DTT)
Royalties to non-residents: 10% (may be reduced under DTT)
Dividends to residents: 0%
Interest to residents: 0%

WHT applies to payments made by Comorian residents to non-residents. The payer is responsible for withholding and remitting the tax to the DGI. Treaty relief requires the recipient to provide a Certificate of Tax Residency and beneficial ownership declaration.

Double Taxation Treaties

Comoros has a limited DTT network. Key treaties include:

France: Comprehensive DTT — dividends reduced to 5-10%, interest 10%, royalties 5-10%
Francophone Africa: Limited treaties with select CFA franc zone countries
Business profits: Only taxable in the source country if there is a permanent establishment
Capital gains: Generally taxable in the country of residence of the seller
Employment income: Taxable in the work country (subject to the 183-day exemption for short assignments)

Comoros has significantly fewer treaties than regional peers. For countries without a DTT, domestic withholding tax rates apply in full. The government is exploring treaty expansion but progress has been limited.

Transfer Pricing

Comoros' transfer pricing rules follow OHADA and francophone African standards. Key requirements include:

Arm's length principle: Transactions between related parties must be conducted as if between independent entities
Documentation: Taxpayers must maintain transfer pricing documentation showing that cross-border related-party transactions are at arm's length
Methods: Acceptable methods include comparable uncontrolled price (CUP), cost plus, resale price, transactional net margin method (TNMM), and profit split
Penalties: Adjustments and penalties apply for non-compliance with arm's length principle

Related parties include parent-subsidiary relationships, sister companies under common control, and individuals with significant influence over a company. The DGI may challenge transfer pricing arrangements that shift profits out of Comoros.

Permanent Establishment Risk

Non-resident companies may create a taxable presence (permanent establishment) in Comoros through: a fixed place of business (office, branch, workshop, construction site exceeding 6 months), a dependent agent with authority to conclude contracts, or provision of services through employees for more than 183 days in any 12-month period. A PE is subject to CIT at the applicable rate on profits attributable to the PE.

Can I repatriate profits from Comoros tax-free?

Dividends paid to non-resident shareholders attract 10% WHT (subject to treaty reduction). Interest and royalties paid to non-residents attract 10% WHT. There is no branch remittance tax on profits remitted by a PE to its foreign head office.

What is the procedure for claiming DTT benefits?

The non-resident must provide the Comorian payer with: a completed Treaty Relief Application form, a Certificate of Tax Residency from the home country tax authority, and a declaration of beneficial ownership. The payer then applies the treaty rate at source. Alternatively, tax can be withheld at the domestic rate and the non-resident can file a refund claim with the DGI.