Cameroon

Overview

The 2020 Finance Law was promulgated on 24 December 2019, and was inserted in the 2020 General Tax Code (GTC), which came into force on 1 January 2020. The Code, and Circular Letter n°006/MINFI/DGI/LRI/L dated 21 February 2020, subjects non-residents supplying electronic services to Cameroonian individuals; services to both Cameroonian individuals (business to consumer [B2C]) and Cameroonian businesses (business to business [B2B]) to the payment of the VAT.

This law requires both resident and non-resident operators of e-commerce platforms that are operational in Cameroon to pay VAT on sales of goods and services carried out on Cameroonian territory and commissions made from these transactions. E-commerce platforms or digital platforms are defined as tools that connect people remotely by electronic means with the aim of selling goods or providing services.

Section 127 (15) of the Code stipulates that commercial operations relating to sales of goods and services carried out on Cameroonian territory or through foreign or local e-commerce platforms are subject to the payment of VAT. Section 127 (16) equally stipulates that commissions received from these commercial operations are equally subject to the payment of VAT.

Section 149 (c) of the Code provides that the VAT due on the sale of goods and services provided through e-commerce platforms shall be calculated, declared, and paid to the Treasury by the non-resident supplier, who is required to register for VAT in Cameroon.

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Key provisions applicable to VAT on ESS
Services in scope
Registration and compliance
Invoicing
VAT on costs
Other considerations

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Release date: April 2024

Key provisions applicable to VAT on ESS

Table 1

Services in scope

This law applies to services of any kind that are provided in Cameroon through electronic platforms by non-resident vendors/suppliers as long as the customer is based in Cameroon. According to the Circular, an electronic platform is a digital tool that electronically connects people with a view to selling a good or providing a service. Such a platform may be used:

by an operator who connects suppliers and customers; and
by a supplier for the distribution of its products or services.

E-commerce platforms are considered foreign platforms when they are operated by non-residents. Similarly, when a non-resident supplier uses a Cameroonian platform, if their supplies are to consumers in Cameroon, then their services would be subject to VAT.

Neither the Finance Law nor its implementing circular lists any specific services that fall within the scope of application.

The scope is, therefore, broad, covering without distinction:

Sales of goods and services carried out on Cameroonian territory or through foreign or local e-commerce platforms
Commissions received by e-commerce platform operators in connection with transactions carried out

Registration and compliance

Non-resident suppliers are required to register themselves with the Cameroon tax authorities. These operators benefit from a simplified registration process that can be done remotely. Suppliers must apply for registration online via the Directorate General of Taxation’s website (www.impots.cm). For platforms already operating in Cameroon, this obligation must be fulfilled within 15 days of the tax administration notifying them of their filing obligations. The tax authorities assume nonresident platform operators have been aware of their obligation to register since 1 January 2020. Non-residents operating newly created platforms must register as soon as they begin operations in Cameroon.

In addition, they are obliged to assess, collect, and remit VAT on all services and commissions received from the performance of services rendered on Cameroonian soil. Where transactions relate to the provision of services, the VAT can be collected and remitted by the platform operator. However, it should be noted that if a service has been acquired via the platform by a taxpayer liable for VAT in Cameroon and the non-resident platform operator has failed to fulfil their obligation to collect and remit VAT, the local customer liable for VAT is exceptionally entitled to assess, collect and pay the VAT (reverse charge mechanism).

Non-resident suppliers are obliged to complete and submit monthly VAT returns online via the Directorate General of Taxation’s website. The deadline for submitting VAT returns and payment of VAT is by the 15th of the month following that in which the services were rendered.

Invoicing

Although non-resident suppliers providing the electronically supplied services are exempt from issuing electronic tax invoices, they are required to issue invoices or receipts showing the value of the supplies made to their Cameroonian customers and the VAT charged. The tax law lays down certain formal requirements for invoices issued. These include certain compulsory information that must appear on the invoice, as defined by the GTC.

The declaration and payment of the VAT by nonresident suppliers of ESS is done via the Directorate General of Taxation’s website (www.impots.cm).

Non-residents are required to pay VAT to the following entity:

“DIRECTION DU TRESOR CAMEROUN” is the recipient of the payment, whose account number is 10 311101 0 1001
The beneficiary bank is the Bank of Central African States (BEAC: Banque des Etats de l’Afrique Centrale), whose SWIFT code is BEACCMCX100
Its IBAN code is FR7630001000640000005104277
The intermediary bank is the Banque de France, whose SWIFT code is BDFEFRPPCCT

In practice, the payment must include the reference for the month concerned and the non-resident’s unique identification number obtained during registration.

VAT on costs

The law does not provide a specific answer for the case of non-resident suppliers of ESS.

The general principle in force in Cameroon is that only persons liable for tax who are registered and subject to the “actual earnings tax system” (i.e., those with an annual turnover excluding tax equal to or greater than FCFA 50 million) and who are on the list of active taxpayers who are up to date with their tax obligations, may recover VAT on costs. This can be obtained through the deduction mechanism. As such, given that the law is not clear on whether nonresident suppliers can recover input tax in Cameroon, the general rules should apply, i.e. VAT borne in Cameroon by these entities should be deductible if they meet the general rules for input tax deduction.

Other considerations

Non-resident suppliers should take note of the Special Income Tax (SIT) levied at a rate of 15% on amounts paid abroad as remuneration for various services provided from abroad but used in Cameroon. This is similar to withholding tax.

Particulars	Description
Scope	B2B and B2C
Liability to remit VAT	By non-resident supplier
VAT rate	19.25%
Taxable value	Price payable by the recipient of the supply
Effective date	B2B and B2C sales from 1 January 2020
VAT registration threshold	Not applicable
Tax invoice	There is a requirement to issue a tax invoice detailing the VAT paid for the services

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