BDO Transfer Pricing News

Cameroon - Cameroon introduces country-by-country reporting

Cameroon on 19 December 2023 introduced a country-by-country (CbC) reporting requirement through the enactment of Law no 2023/019, the Finance Law for fiscal year 2024. 

The legislative measure marks a significant development in the nation’s financial landscape. The introduction of CbC reporting is expected to furnish the tax authorities with comprehensive insights into the economic activities (including revenues, profits, and tax outcomes) of multinational enterprises (MNEs) within each jurisdiction in which they operate. This development underscores the government’s commitment to enhancing transparency and facilitating effective tax administration in alignment with international standards. 

The new law mandates that any MNE operating in Cameroon must submit electronically a CbC report within 12 months after the conclusion of the tax year. The rules are effective from 1 January 2024, meaning that in-scope Cameroonian taxpayers with a 31 December 2024 year-end will be obligated to comport with the regulations by 31 December 2025.   

Taxpayers that meet the following criteria in Cameroon are potentially in scope of the new regulations: 

  • They are part of an MNE group and are established in Cameroon; 

  • They are required to file consolidated financial statements, or would be required to do so if their shares were listed  on the Central African Stock Exchange; and 

  • They had consolidated group turnover of at least XAF 492 billion -- approximately EUR 750 million -- in the preceding fiscal year. 

Cameroonian taxpayers that are part of an MNE group and are owned directly or indirectly by a foreign entity are not obligated to submit a CbC report under conditions similar to the recommended rules issued by the Organisation for Economic Co-operation and Development in their guidance on CbC reporting:  

  • An ultimate parent entity (or surrogate parent entity) or “reporting entity” has submitted a CbC report in its jurisdiction (as required by that jurisdiction’s regulations) and that jurisdiction has concluded an agreement authorising the automatic exchange of CbC reports with Cameroon; 

  • The jurisdiction of tax residence of the reporting entity has not informed Cameroon of a systemic failure; and 

  • A constituent entity tax resident in Cameroon has submitted a notification indicating the identity and jurisdiction of tax residence of the reporting entity. 

The content of the CbC report and a list of jurisdictions that have concluded an agreement authorising the automatic exchange of CbC reports will be determined by order of the minister in charge of finance. The form and manner of submitting a CbC notification is not provided in the new regulations.  

MNEs with operations in Cameroon should assess whether they are potentially in scope of the CbC reporting regulations in Cameroon for years beginning on or after 1 January 2024.  

If you have any questions, please contact the author(s) or reach out to one of our Global Transfer Pricing professionals

Marcus Stelloh 
Patrick Grant McLennan 
BDO in South Africa 


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