Financial Account Information Reporting and Exchange

Cameroon acceded to the OECD Mutual Assistance Convention as amended and the convention entered into force for Cameroon on 1 October 2015. Cameroon has signed the Common Reporting Standard (CRS) Multilateral Competent Authority Agreement and has proposed adoption of measures to implement the automatic exchange of financial account information in accordance with the global standard for exchange of information developed by the OECD under the CRS by September 2026. In preparation of the forthcoming exchange, the Finance Law 2024 introduced an obligation for banks and other financial institutions to communicate financial account information to the tax authorities.

There is as yet no FATCA agreement with the United States.

Payments to Tax Haven Entities

Payments made in remuneration of transactions of any kind to legal entities or individuals’ resident in tax havens are not deductible unless the following conditions are met:

The payment is in remuneration of the acquisition of goods or merchandise produced in the relevant country or territory;
The goods or merchandise have cleared Customs in Cameroon; and
When the deduction is allowed, it also covers remunerations for related services, if any.

A higher withholding tax rate of 33% (30% plus 10% council surtax) applies on certain payments to non-residents established in a territory or state considered as a tax haven (see Sec. 8.2.2.).

Further, the transfer pricing rules apply to all transactions with tax havens, including those undertaken with unrelated parties established therein (See Sec. 13.4.).

For these purposes, a tax haven is defined as one where the applicable tax rate is less than one third of the rate applicable in Cameroon or as jurisdictions considered as non-cooperative in matters of transparency and exchange of information for tax purposes by OECD.

Ultimate Beneficial Ownership Register

Effective 27 September 2023, resident companies are required to disclose information on their beneficial owners. New companies are required to disclose the information on their beneficial owners within 30 days of incorporation of the company. In case of any change in beneficial ownership information, such change must be reported within 45 days. The information is required to be continuously updated and maintained during the period that a person is a beneficial owner, and for 5 years after the termination of such status.

For this purpose, a beneficial owner is a natural person that owns a significant interest in or exerts significant control over the Cameroon company, including a person who:

Holds, directly or indirectly, more than 20% of the issued shares in the company or, if the company does not have a share capital, the person is, directly or indirectly, entitled to more than 20% of the capital or profits of the company;
Holds, directly or indirectly, more than 20% of the voting rights of the company; or
Has the right to exercise, or actually exercises, significant influence or control over the company.

If no natural person can be identified as beneficial owner based on aforesaid conditions, the principal manager of the company is treated as the beneficial owner.

Failure to comply with the reporting requirements attracts a fine of up to XAF 5 million.

Indirect Transfer of Assets

Capital gains derived by non-residents on the sale or indirect transfer of assets located in Cameroon (including mineral and similar rights) are subject to corporate tax in Cameroon. Effective 1 January 2023, the Cameroon company whose shares, bonds or any other assets are indirectly transferred by non-residents is obligated to report such transfer to the tax authorities within 15 days from the date of signing of the contract of transfer, with an extension of up to 3 months available in certain cases. The Cameroonian company is also required to file detailed valuation reports, audit reports and other supporting documents for the said indirect transfer of assets located in Cameroon.

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