2026 Finance Law in Cameroon: The End of “Invisible” Business

2026 Finance Law in Cameroon: The End of “Invisible” Business

For decades, the definition of doing business in Cameroon was simple: you were here when you physically arrived. If you rented an office, hired staff, or built a factory, you were taxable. If you operated from abroad, sending digital services or goods without a local footprint, you were largely invisible to the tax administration.

This belief—that physical absence equals fiscal immunity—is no longer valid. The 2026 Finance Law in Cameroon has fundamentally rewritten the rules of engagement. With the introduction of the “Significant Economic Presence” (SEP) in Section 5, the government has moved the tax border from the physical ground to the digital cloud.

This article explains what Section 5 changes, why it matters for your business strategy, and how to navigate this new reality without panic.

The Shift from Physical to Economic Presence

In the past, international tax treaties and the General Tax Code focused on the concept of a “Permanent Establishment.” This usually meant walls, desks, and a manager. If a foreign company did not have these, they could generate significant revenue in Cameroon without paying Corporate Income Tax (CIT).

The 2026 Finance Law in Cameroon closes this loophole. Section 5a now states that a non-resident enterprise is deemed to be operating in Cameroon if it has a “Significant Economic Presence.” This means the tax authority no longer looks for your office keys; they look for your digital footprint. If you have a substantial connection with the national territory, you are liable for tax, regardless of where your headquarters are located.

Understanding the New Digital Thresholds

The law is very specific about who falls into this net. It introduces quantitative thresholds that are surprisingly easy to reach. Under Section 5b, a foreign company is taxable if it meets just one of the following criteria during a financial year:

1. Revenue Threshold: It invoices more than 50 million FCFA for digital services to customers in Cameroon.
2. User Threshold: It has more than 1,000 users, customers, or account holders based in Cameroon.

This second point is critical. A “user” does not necessarily mean a paying corporate client. It could include account holders on a free app or subscribers to a streaming service. The bar of 1,000 users is low enough to catch many mid-sized SaaS platforms, fintech apps, and e-learning providers that previously flew under the radar.

What Counts as a Digital Service?

You might think this only applies to tech giants. However, the 2026 Finance Law in Cameroon defines “digital services” broadly. The list in Section 5 includes:

• On-demand content like streaming, downloading, and online gaming.
• Online advertising and data monetization services.
• Intermediation fees from electronic marketplaces (like commissions on freelance or e-commerce platforms).
• Cloud computing, data hosting, and Software as a Service (SaaS).

Consequently, if your business relies on foreign software or if you are a foreign vendor selling to the Cameroonian market, the cost structure is about to change.

The Clarification of the “Full Business Cycle”

Beyond the digital economy, the new law tightens the screws on traditional trade. Section 5a(2) clarifies the concept of a “Full Business Cycle.”

Previously, some foreign traders argued that they were merely selling goods to Cameroon, not operating in Cameroon. The new text specifies that if you carry out a coherent set of operations—buying or producing goods and then reselling them—within the national territory, you are taxable. This applies even if you do not meet the digital thresholds.

Furthermore, Section 5c reinforces the “Territoriality Principle” for air and maritime transport. Airlines and shipping companies, whether established locally or abroad, are now explicitly subject to Corporate Income Tax on profits earned in Cameroon. This removes ambiguity and signals aggressive enforcement on freight and ticket revenues.

Consequences You Might Not See Immediately

The most dangerous consequence of the 2026 Finance Law in Cameroon is not the tax itself, but the hidden inflation it causes.

If you are a local business, you may not be the direct target of Section 5. However, your suppliers are. When foreign software providers, cloud hosts, or digital marketers realize they are now liable for 30% CIT in Cameroon, they will likely pass that cost on to you. You may see invoices increase by 10% to 20% in the first quarter of 2026.

If you are a non-resident entrepreneur, the risk is compliance. Ignorance is no longer a defense. The law allows the administration to use IP addresses, geolocation, and billing addresses to prove your presence. A “Notice of Adjustment” sent to your email two years from now will carry heavy penalties.

A Better Way to Prepare

The goal of this analysis is not to induce fear, but to provide clarity. The 2026 Finance Law in Cameroon is simply modernizing the tax system to match the digital reality.

Read Also: Why the 2026 Finance Law Matters Now

To stay ahead, you need a proactive mindset:

• Audit Your Tech Stack: Identify which foreign digital services are critical to your operations and anticipate price hikes.
• Check Your User Base: If you are a foreign entity, check your Cameroonian user count. Are you approaching the 1,000-user mark?
• Review Contracts: Ensure your agreements with foreign partners account for potential withholding tax obligations.

At OpenHub, we specialize in translating these complex legal shifts into safe business strategies. Whether you need a compliance audit through OpenHub Consulting or training for your finance team via the OpenHub Academy, we are here to help you go through the transition.

The rules have changed. By understanding Section 5 today, you ensure that your business remains not just compliant, but competitive in the year ahead.