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12.5. Other Anti-Avoidance Rules

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; and
  • The goods or merchandise have cleared Customs in Cameroon.
  • When the deduction is allowed, it also covers remunerations for related services, if any.

Further, the transfer pricing rules apply to all transactions with tax havens, including those undertaken with unrelated parties established therein (See sec 12.4.).

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.

Reporting Obligation in Certain Cases

In case of any significant modification affecting the business such as change of manager, direct or indirect transfer of shares or corporate units, cessation, modification of business name, modification of capital structure or shareholding, modification of activity or place of activity, the taxpayer must make declaration within 15 working days of the modification. Effective 1 January 2021, the said time limit is extended to 3 months where such modification is made abroad.