Worldwide transfer pricing reference guide 2014

Cameroon
Taxing authority and tax law
Tax authority: General Director of Taxation
Tax law: General Tax Code
Relevant regulations and rulings
Circular on the Finance Law by the General Director of Taxation.
OECD guidelines treatment
Cameroon does not make any specific reference to the OECD Guidelines but refers to the arm’s length principle.
Priorities/pricing methods
Not applicable.
Transfer pricing penalties
There are no specific rules for transfer pricing adjustments but generally all tax adjustments are subject to penalties.
Penalty relief
In case of partial or total failure to submit the required documentation, a notice to provide or complete the documentation will be served
within 30 days to the company. This notice should remind the taxpayer of the penalties in case of failure to reply, including adjustments
based on information available to the authority.
The taxpayer should make all attempts to submit the transfer pricing documentation within the deadline provided i.e., 15 March of
each year.
Documentation requirements
Article 18-3 of the New Finance Law 2014 stipulates that:
“Companies falling under the Department in charge of large enterprises shall also submit within the same deadline and using the form
provided by the Administration, the statement of shares which they own in other companies where such shares do not exceed 25% of
their share capital. They shall attach a detailed statement of transactions with the companies which control them or which are under
their control, be they in Cameroon or abroad. For the application of this provision, the notion of control must be understood as used in
Article M 19 (a) (2) of the Tax Procedures Manual.“
The documents to be included in the annual tax return are:
A statement of ownership in other companies if the ownership exceeds 25% of their share capital. The statement should be
accompanied by the following elements:
• A general description of the ownership, including changes in securities occurred during the last two years of activities
• A general description of the legal and operational structures of the associated companies, including an identification of the associated
structures engaged in transactions with the company
• A general description of the functions performed and risks assumed by the associated companies that affect the company and its
business reporting
• A list of key intangible assets, including patents, trademarks, trade names and know-how related to the company filing the return
A detailed statement of the intra-group transactions:
• A description of transactions with other affiliates, including the nature, amount of flows, and fees
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