Gabon cross-border tax

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.

2026 draft and currency hold. This is a research draft for 2026, not a certified consolidation of the law in force. The DGI-hosted 2025 CGI is a historical baseline, read alongside enacted Law 041/2025 of 29 December 2025 and Law 002/2026 of 17 July 2026. The complete intervening amendment chain, transaction-specific commencement and implementing instruments have not been established. Do not use a baseline figure as an operative 2026 filing instruction. A July amendment is identified as such; its promulgation date alone does not establish its first taxable period. No independent pack review or accountant attestation has occurred.

Who this applies to

Individuals arriving or departing and businesses paying or receiving cross-border income. Establish residence, source, recipient capacity, installation and treaty position separately. Corporate-source rules and individual worldwide-income rules are different. CGI art7-I (ledger C-SCOPE); CGI art74 (ledger I-SCOPE); CGI art162 (ledger I-WORLD). This is a domestic-law decision reference, not a treaty-rate table.

Rates, bands and thresholds

Item and conditions	Rule or amount (XAF unless stated)	Period/status	Official source
Covered nonresident professional/service/IP payments	25% of gross excluding turnover taxes, only where article 206 conditions hold	2025 statutory baseline; 2026 currency hold	CGI art206 (ledger X-WHT)
Ordinary movable-capital levy	20%; payment or account-credit event, exceptions and treaty conditions apply	2025 statutory baseline; 2026 currency hold	CGI arts108-111 (ledger X-DIV)
Construction and related supervision	More than three months; do not substitute the services day-count rule	2025 statutory baseline; 2026 currency hold	CGI art7-II (ledger X-PE)
Same or connected services project	More than 183 days in any twelve-month period, subject to full PE and treaty analysis	2025 statutory baseline; 2026 currency hold	CGI art7-II (ledger X-PE)
Departure provisional declaration	At least 30 days before departure	2025 statutory baseline; 2026 currency hold	CGI arts165-166 (ledger X-EXIT)
Covered direct or indirect share gains	25% final levy collected by the Gabon company within one month	Initial 2026 law; transaction-date and full-chain hold	LF041/2025 art4, CGI art23para6 (ledger X-GAIN)
OCAM convention	Ceases effects for Gabon from 1 January 2026; other valid conventions and pre-2026 facts have separate rules	July 2026 enacted art7 expressly names 1 January	LFR002/2026 art7 (ledger X-OCAM)

The base

Classify the payment before selecting a rate. Article 206 covers specified independent activity, IP, services materially supplied or actually used in Gabon and professional fixed-income receipts paid by a Gabon debtor to a recipient without a professional permanent installation. It is not a flat tax on every foreign payment. CGI art206 (ledger X-WHT). Ordinary movable-capital treatment has separate rules and exceptions for specified instruments and recipients; do not assume all interest is classified alike. CGI arts108-111 (ledger X-DIV). Gross-up requires the contract and a separately verified computation.

PE analysis starts with fixed place, management, branch, office, extraction, construction, services and agents. Auxiliary exclusions are limited by anti-fragmentation; the specific project-duration tests do not override an independently existing fixed-place PE. CGI art7-II (ledger X-PE). For individuals, entry residence begins its own income scope; departure includes income acquired but not yet received and proof or security for unpaid taxes. CGI arts165-166 (ledger X-EXIT).

Deadlines and filing

Article 206 withholding is remitted in the first fifteen days after the payment month, using the authority return and receipt. Movable-capital levies have their own thirty-day remittance period. Covered share-gain collection is a further distinct one-month duty, not the ordinary service return. CGI art206 (ledger X-WHT); CGI arts108-111 (ledger X-DIV); LF041/2025 art4, CGI art23para6 (ledger X-GAIN). Departure provisional returns can be completed within the first two months of the following year and require tax-clearance evidence and an employer/bank undertaking or security as applicable. CGI arts165-166 (ledger X-EXIT).

The public e-tax link does not prove a complete filing route. This draft has not inspected an authenticated account, current return identifier, box numbers, payment reference generation or acceptance receipt. Obtain the current authority form and preserve the accepted declaration and payment receipt before treating the job as complete.

Penalties and interest

The baseline late-return rule is 5% of declared rights before formal notice, or 10% if filed within seven days after notice. Failure after notice moves to ex officio assessment and separate sanctions. Nil, deficit and missing-annex returns have their own fixed penalties; do not apply a percentage to zero and call the penalty zero. CGI artsP998-999 (ledger G-DELAY). July 2026 replaces the DGE/CIME late or incomplete electronic-payment rule with a 10% penalty plus article P-996 interest and excludes collection penalties when P-998 late-filing penalties apply. For an actual default, establish its date, taxpayer service and procedural notices before computing. LFR002/2026 art4, CGI artP1000 (ledger G-PAY). A payment classification error, departure-clearance default and missing withholding declaration do not necessarily share one sanction base.

Cross-border points

Law 002/2026 article 7 expressly ends OCAM effects from 1 January 2026, preserves other regularly effective conventions and opposable commitments, and distinguishes pre-2026 established situations. Do not grant an OCAM exemption from an old country list. For another treaty, obtain the actual ratified published text, applicable year, residence evidence, beneficial-entitlement conditions and relief procedure. None is inferred here. LFR002/2026 art7 (ledger X-OCAM). Nonresident VAT and the digital option are separately addressed in VAT; simplified VAT registration alone does not establish a corporate PE. LFR002/2026 art4, CGI arts248septies-248nonies (ledger V-DIGITAL).

Two worked examples that recompute

Covered service, no treaty relief proved. Assume article 206 conditions are satisfied and gross service remuneration excluding turnover taxes is 1,000,000. Withholding is 250,000 and cash after that withholding is 750,000, before any other tax or contractual gross-up.

name: Nonresident service withholding baseline
inputs:
  gross: 1000000
steps:
  - withholding: gross * 0.25
  - cash: gross - withholding
expected:
  withholding: 250000
  cash: 750000

Decision: professional service or ordinary movable income. On 1,000,000, a proven article 206 service gives 250,000. A separately proven ordinary article 109 movable-income payment gives 200,000. The 50,000 difference is why payment nature and recipient capacity must be established. These are alternative factual classifications, not an election and not invented treaty rates.

name: Decision classify payment before rate
inputs:
  gross: 1000000
steps:
  - service_tax: gross * 0.25
  - ordinary_movable_tax: gross * 0.20
  - difference: service_tax - ordinary_movable_tax
expected:
  service_tax: 250000
  ordinary_movable_tax: 200000
  difference: 50000

Ask the client first

• Who pays and receives, with what legal and tax residence?
• What is the actual payment, contract, use, recipient capacity and tax-inclusive pricing?
• What offices, people, agents, days and connected projects exist in Gabon?
• Which treaty text, residence certificate and relief procedure are evidenced?
• For a move or share transfer, what dates, value, cost, income accruals and clearance records exist?

Sources

Source and actual read scope	Official URL	Read on
CGI: Read the cover amendment list and selected passages from arts 2-3, 4-7 (including PE thresholds and exceptions), 8-11 introduction and 11-IV, 12-28, 73-80, 90-96, 108-114, 162-178bis, 206-209, 211-224, 235-243ter, 346-351, P-816-819, P-826-832, P-996-1010ter and TFNC CSS arts 13-27. Exact read rules are the matched ledger quotes; this is not a claim that every paragraph across those ranges was read.	https://dgi.ga/wp-content/uploads/dgi-content/d1dde772234076c5d2bc0a8d8d3db573ed3d8fdd6c3e869c8c57cd181a81bb70/assets/dgi/2d50ab6c2e-Gabon-CGI-2025.pdf	2026-11-01
LFR: Read enacted identity; fiscal amendments printed1-16 including arts11bis,91bis,178bis,202-204,208ter,210,211ter,215,221-224,227,230,243bis,248septies-nonies,401-404bis,P832ter,P1000; art7 OCAM withdrawal and final101-102/promulgation. Other fiscal measures read for screening only; budget annexes not reviewed.	https://dgb-gabon.net/uploads/documentation/Texte%20juridique/178593988623.pdf	2026-11-01
LF: Read enacted identity and arts 1-4 with selected fiscal amendments on printed pages 1-5 and 15-18; detailed reconciliation of art11,23,178bis,210,221,223, deletion234, P832ter-quinquies/P917/P1000; final arts78-79/promulgation printed69-70. Customs and budget schedules not used.	https://dgb-gabon.net/uploads/documentation/Texte%20juridique/178946560179.pdf	2026-11-01

Not yet confirmed: Treaty partners, rates, ratification and relief forms; beneficial-ownership and anti-abuse conditions for any claimed treaty; complete indirect-share-gain mechanics; professional versus passive interest exceptions; departure portal and clearance procedure; customs, exchange-control and social-security agreements. Complete intervening amendments, date-specific commencement, current forms and boxes, and independent review. See the country evidence and old-topic destination map.