Worldwide transfer pricing reference guide 2014

Cameroon (continued)
Documentation requirements (continued)
• A list of cost sharing agreements and, if applicable, a copy of the preliminary agreements on transfer pricing and rescripts relating to the
determination of transfer prices, affecting the results of the enterprise filing the return
• An overview of the methods and the determination of transfer prices in accordance with the arm’s length principle, including an analysis
of the functions performed, assets used and risks assumed and an explanation for the selection and application of or the methods used
• A comparative analysis of the elements considered relevant for the company
Documentation deadlines
The transfer pricing documentation must be submitted each year along with the annual tax return no later than 15 March.
Statute of limitations on transfer pricing assessments
The statute of limitations on transfer pricing assessment is four years.
Return disclosures/related party disclosures
Tax payers must disclose related party transactions. Indeed, the provisions of Article 18-3 indicate that the company must provide a
description of transactions with other affiliates, including the nature and amount of flows, including fees. These disclosures are to be
included in the transfer pricing documentation submitted with the return.
Transfer pricing-specific returns
As of this point, the administration has not provided a standard template or submission form.
Audit risk/transfer pricing scrutiny
The likelihood of an annual tax audit in general is high. The likelihood that transfer pricing will be reviewed as part of that audit is also
high. However, the likelihood that the transfer pricing methodology will be challenged is low.
APA opportunity
Advanced Pricing Agreement L 33 provides for some agreements for operations between the taxpayer and the authorities but no
specific reference is made to transfer pricing agreements.
Expected reaction to OECD Report on BEPS
Even prior to the introduction of stringent transfer pricing requirements, Cameroon had a general anti-avoidance rule, which stated that
in case of any agreement or legal act concealing the direct or indirect transfer of income or benefits, the tax authorities have the right
to restore the transaction to its true substance and to reassess the taxable amounts. In addition, the Finance Law 2012 disallowed the
deductibility of certain expenses when paid to recipients which are residents in tax havens jurisdictions.
Apart from the aforementioned, there has been no reaction on the OECD Report on BEPS from the Cameroonian tax authorities.
Worldwide transfer pricing reference guide
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