Cameroon: Guidance on mutual agreement procedures (MAPs)

Cameroon’s tax authority in October 2025 published Circular No. 033, providing guidance on mutual agreement procedures (MAPs) within its income tax treaties.

The guidance includes clarifications on the following:

• Basis of the MAP: The MAP is a non-judicial procedure aimed at ensuring the proper application and interpretation of tax treaties based on the OECD Model Tax Convention on Income and Capital, and the UNO Model Convention on Double Taxation between developed and developing countries.
• Scope of the MAP: Circular No. 033 applies to any individual or legal entity that is a tax resident of Cameroon or of a state party to the relevant income tax treaty and that may request the initiation of the MAP.
• Income taxes concerned: This procedure includes all taxes covered by the relevant income tax treaty, including individual (personal) income tax; corporation tax; minimum flat-rate tax; synthetic income; special tax on income; contributions to the housing fund and all relevant taxes based on salaries; and special levies on fees and other remunerations for studies, technical, financial, and accounting assistance.
• How the MAP works:
  • MAP request must be addressed to the competent authority, subject to certain conditions being met within the time limits. In Cameroon, the competent authority for receiving requests for MAPs is the Minister of Finance (MoF) or a duly authorized representative.
  • MAP request must include essential information listed in Circular No. 033, including the identity of the taxpayer(s); the tax treaty on which the request for mutual agreement procedure is based; the taxes, tax years, and amounts involved; and a copy of the collection notices and adjustment notifications.
  • MAP request must be addressed to the competent authority within the time limit specified in the tax treaty. In the absence of a time limit for referrals provided for in the treaties, the MAP request may be submitted to the competent authorities within a period of three years.
• Cases that exclude the MAP:
  • When the taxpayer fails to provide evidence of double taxation
  • Failure to comply with the deadlines for initiating a MAP
  • Foreclosure of the MAP request addressed to an incompetent authority (other than the MoF or a duly authroised representative)
  • When the taxpayer does not intend to comply with the principles set forth in the applicable tax treaty
    
• Possible outcomes of the MAP
  • Unilateral settlement of the MAP by one of the competent authorities that are parties to the relevant tax treaty.
  • An agreement between the competent authorities of the state’s parties to the relevant tax treaty to eliminate double taxation entirely or in full.
  • An agreement between the competent authorities of the state’s parties to the tax treaty on the absence of taxation or double taxation.
  • A disagreement between the competent authorities.

KPMG observation

A request for a MAP does not suspend the enforcement of tax collection measures. Therefore, the taxpayer must ensure that payment measures are suspended within the framework of the tax litigation procedure. In addition, taxpayers who accept the terms of the MAP waive all rights to tax litigation, both on substantive and procedural grounds.

For more information, contact a KPMG tax professional in Cameroon:

Theophile Tchafack | ttchafack@kpmg.cm

Peter Ngwa | pngwa@kpmg.cm