The enactment of Law No. 2025/012 of 17 December 2025 marks a historic shift in Cameroon’s fiscal jurisdiction. For the first time, the "Permanent Establishment" concept has been expanded to include a Significant Economic Presence (SEP) standard, targeting non-resident digital service providers who generate value in Cameroon without a physical office.
The General Tax Code (GTC) establish that a foreign entity is taxable in Cameroon if it meets either of these criteria in a tax year:
- Revenue: Gross receipts from digital services (streaming, SaaS, cloud hosting, online advertising) exceed FCFA 50 million.
- Users: Maintaining more than 1,000 active users or account holders located within the national territory.
A cornerstone of the 2026 reform is the suppression of the Simplified Tax System (previously for entities with turnover between FCFA 10M and 50M). This removal creates a binary fiscal landscape:
- Impôt Global Synthétique (IGS): This synthetic tax now covers micro-enterprises. It consolidates various small levies into a single payment for very low-turnover entities.
- Régime du Réel (Actual System): Most formal SMEs formerly under the simplified regime must now transition to the Actual System. This mandate full Organisation for the Harmonisation of Business Law in Africa (OHADA)-compliant accounting, as the "middle ground" of simplified reporting no longer exists.
Article 21 prescribes a simplified tax rate of 3% on gross turnover generated in Cameroon by SEP entities. Fundamentally, Article 23 bis mandates that all non-resident entities must register and file monthly returns through the new DGI Digital Portal by the 15th of each month. The law also empowers local banks and telecom operators to act as withholding agents if foreign entities fail to comply, effectively cutting off revenue streams from the source.
For international investors, the transition from "Simplified" to "Actual" compliance, paired with the SEP sourcing rules, creates a complex technical challenge.
Reference/Citation
- Law No. 2025/012 of 17 December 2025: Finance Law for the 2026 Financial Year | Republic of Cameroon https://www.prc.cm
- Cameroon: Significant Economic Presence Standard Introduced from 2026 | KPMG Global –https://kpmg.com/us/en/taxnewsflash/news/2025/12/cameroon-sep-standard-from- 2026.html
- General Tax Code (CGI) 2026 Edition: Articles 5 bis, 5 ter, 21, and 23 bis | Directorate General of Taxation (DGI) – https://www.impots.cm
