Cameroon transfer pricing

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

Who this applies to

Companies dependent on, or controlling, companies in or outside Cameroon (CGI art. 19). A link exists at 25% of capital or votes, by actual decision power, or under common control (art. 19 bis). No link is needed for transfers to a tax haven or privileged regime (art. 19(2)).

Rates, bands and thresholds

Item	Rate or amount	Source
Link test	25% of capital or votes	CGI art. 19 bis: https://www.impots.cm/sites/default/files/documents/CODE%20GENERAL%20DES%20IMPOTS%202026%20SITE%20DGI%20VERSION%20FRANCAISE.pdf
Documentation limit	Turnover or gross assets of XAF 1 billion or more; or a holding over 25% tied to such a firm	LPF art. L 19 bis: https://www.impots.cm/sites/default/files/documents/CODE%20GENERAL%20DES%20IMPOTS%202026%20SITE%20DGI%20VERSION%20FRANCAISE.pdf
Country-by-country group limit	Consolidated turnover of XAF 492 billion or more	CGI art. 18 quater: https://www.impots.cm/sites/default/files/documents/CODE%20GENERAL%20DES%20IMPOTS%202026%20SITE%20DGI%20VERSION%20FRANCAISE.pdf
Country-by-country deadline	12 months after year end	CGI art. 18 quater: https://www.impots.cm/sites/default/files/documents/CODE%20GENERAL%20DES%20IMPOTS%202026%20SITE%20DGI%20VERSION%20FRANCAISE.pdf
Fine for arts. 18 ter, 18 quater, L 6 bis	XAF 50,000,000	LPF art. L 104(2): https://www.impots.cm/sites/default/files/documents/CODE%20GENERAL%20DES%20IMPOTS%202026%20SITE%20DGI%20VERSION%20FRANCAISE.pdf
Tax-haven test	Tax under one third of Cameroon's, or non-cooperative	CGI art. 8 ter: https://www.impots.cm/sites/default/files/documents/CODE%20GENERAL%20DES%20IMPOTS%202026%20SITE%20DGI%20VERSION%20FRANCAISE.pdf

The base

Profits moved through prices or otherwise are added back, by comparison with what independent firms would have earned (art. 19(1)).

Deadlines and filing

Large enterprises unit members file the annual transfer pricing declaration electronically by the art. 18 date, 15 March (art. 18 ter). Documentation must be ready in electronic form when an audit starts (art. L 19 bis). Its content is set by the arrete printed in the CGI annexes.

Penalties and interest

A missing, late, incomplete or non-compliant declaration draws the XAF 50,000,000 fine (art. 18 ter(3), L 104(2)). Tax on the add-back carries the normal penalties (art. L 95, L 96).

Cross-border points

Treaties may give a mutual agreement route; check the treaty. An advance agreement on method exists in the LPF; its article was not read in full.

Two worked examples that recompute

name: Royalty 500 million, arm's length 300 million, 33 percent with CAC
inputs:
  paid: 500000000
  arm: 300000000
steps:
  - addback: paid - arm
  - tax: addback * 0.33
expected:
  addback: 200000000
  tax: 66000000

name: Same add-back at 25 percent, good faith penalty
inputs:
  addback: 200000000
steps:
  - tax: addback * 0.25
  - penalty: tax * 0.30
  - cac: (tax + penalty) * 0.10
  - total: tax + penalty + cac
expected:
  tax: 50000000
  penalty: 15000000
  cac: 6500000
  total: 71500000

Ask the client first

1. Group chart and holdings at 25%?
2. Turnover and gross assets of each Cameroon entity?
3. Which tax office manages the company?
4. Group consolidated turnover?
5. Any payee in a low-tax place?

Sources

Source	URL	Read on
Code General des Impots, Edition 2026 (DGI): arts. 8 ter, 18 ter, 18 quater, 19, 19 bis, L 19 bis, L 104, documentation arrete in annexes	https://www.impots.cm/sites/default/files/documents/CODE%20GENERAL%20DES%20IMPOTS%202026%20SITE%20DGI%20VERSION%20FRANCAISE.pdf	2026-11-01

Not yet confirmed: the DGI transfer pricing instruction (a scan, 47 pages, not read); the methods list; the advance agreement article; the audit-limit extension.