Cameroon has adopted Country-by-Country Reporting (CbCR) regulations as part of its efforts to enhance tax transparency and align with global standards established under the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13. The Cameroonian Tax Administration oversees the implementation and compliance of these regulations.

This guide provides essential information for Chief Financial Officers and tax directors of multinational enterprises (MNEs) operating in Cameroon, detailing their obligations, reporting requirements, deadlines, penalties, and key resources.

Applicability of CbCR in Cameroon

Criteria for Reporting:

• CbCR obligations apply to multinational enterprise (MNE) groups that:
  • Have consolidated group revenue exceeding XAF 492 billion (Central African CFA francs, approximately €750 million) in the preceding fiscal year.
  • Include an entity that is tax-resident in Cameroon, either as the Ultimate Parent Entity (UPE) or a subsidiary.

Local Filing Obligations:

• Local entities in Cameroon must file the CbC report if:
  • The UPE is not obligated to file in its home jurisdiction, or
  • There is no exchange of CbCR information between the UPE’s jurisdiction and Cameroon.

Relevant Legislation:

• The framework for CbCR in Cameroon is established under Law No. 2018/011 of December 11, 2018, which amended the General Tax Code to incorporate BEPS Action 13 requirements.

Reporting Requirements

Content of the CbC Report:

• The report must include aggregated financial data for each jurisdiction where the MNE operates, covering:
  • Revenue (related and unrelated party transactions),
  • Profit or loss before tax,
  • Income taxes paid and accrued,
  • Stated capital and retained earnings,
  • Number of employees,
  • Tangible assets (excluding cash and cash equivalents).

Filing Notifications:

• Local entities must notify the tax administration of the identity and tax residence of the reporting entity (either the UPE or surrogate parent entity) within their group.

Submission Platform:

• Reports are submitted to the Cameroonian Tax Administration electronically, adhering to the prescribed format based on OECD XML schema.

Resource:
For further details, consult the Ministry of Finance’s official portal: Ministry of Finance, Cameroon.

Filing Deadlines

• The CbC Report must be filed within 12 months of the fiscal year-end of the MNE group.
  • For instance, if the fiscal year ends on 31 December 2023, the CbCR filing deadline is 31 December 2024.
• Notification of the reporting entity must be provided by the end of the fiscal year.

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Penalties for Non-Compliance

Failure to Comply:

• Non-compliance with CbCR obligations in Cameroon can result in:
  • Significant financial penalties for failure to file, late filing, or providing incorrect information.
  • Additional scrutiny or audits from the tax administration.

Reasonable Justification:

• The Cameroonian Tax Administration may waive penalties if a taxpayer demonstrates reasonable cause for non-compliance.

Confidentiality and Exchange of Information

Data Protection:

• CbC reports are protected under Cameroonian tax laws and used solely for:
  • Assessing transfer pricing risks,
  • Ensuring compliance with international tax obligations.
• Cameroon exchanges CbC reports with other jurisdictions under international agreements, provided confidentiality and proper data use are assured.