CAMEROON Trends and Developments Contributed by: Lynda Amadagana, Elise Ngo Nyobe, Hervée Belinga and Abel Esseba, Amadagana & Partners
• agriculture, livestock and fisheries; • heavy industry, automotive and manufacturing; • education and health; • air, rail and maritime transport; • tourism and leisure; and • digital data storage and processing infrastructure. The upstream oil, mining and gas sector, as well as the trade and distribution sector, are governed by sector-specific legislation which also offers various incentives. Moreover, the legislation has extended several target - ed customs duty exemptions from 1 January 2026, in particular: • 24 months for medical equipment; • 12 months for equipment related to renewable energy and water; and • extension of these exemptions to digital start-ups and equipment intended for persons with disabili - ties. These measures reflect a clear orientation towards the promotion of sectors deemed priorities, namely health, the energy transition and technological innova - tion. In parallel, there has been a tightening of export taxation, with: • a 5% tax on the free-on-board (FOB) value of min - eral ores; and • a 10% levy on marble and clinker. This approach confirms a policy of maximising the local value of natural resources and limiting the export of unprocessed raw materials. Taxation The Finance Law for FY 2026 defines the condi - tions for budgetary and financial balance, while also improving the business environment and promoting tax compliance. The concept of significant economic presence One of the major innovations lies in the introduction of a digital taxation regime based on the concept of significant economic presence. In accordance with the provisions inserted into the General Tax Code (in
particular, Articles 5 bis and 5 ter), non-resident com - panies providing digital services in Cameroon are now liable to taxation once they exceed certain thresholds, for example: • local turnover in excess of approximately XAF75,000 (or the equivalent threshold in XAF); or • more than 1,000 active users, customers or accounts. Such entities are subject to either: • a withholding tax of 3% on their gross turnover; or • failing that, a flat-rate tax equivalent to 10%. This mechanism brings Cameroon closer to interna - tional trends in the taxation of the digital economy, particularly in systems inspired by OECD practices and those of certain other African jurisdictions. Strengthening of tax audits and digitalisation of the administration The 2026 Finance Law also introduces tools to enhance the effectiveness of tax audits: • a mandatory annual certified tax review for compa - nies with a turnover exceeding XAF1 billion; • introduction of real-time taxation mechanisms; • increased use of AI by the customs administration; and • broader access to beneficial ownership registers. Public-Private Partnerships (PPPs) Law No 2023/008 of 25 July 2023, establishing the general framework for public-private partnership con - tracts, constitutes the most significant reform of Cam - eroon’s PPP regime in over a decade. It replaces the 2006 framework and introduces a clearer distinction between three categories of PPP: • publicly funded PPPs; • concession-based PPPs (build–operate–transfer or BOT, build–own–operate or BOO, concession, lease, etc); and • mixed-payment PPPs. This clarification addresses a difficulty long encoun - tered by investors and banks alike: uncertainty sur -
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