The 1976 France-Cameroon tax treaty, read article by article

The convention between France and Cameroon was signed in Yaoundé on October 21, 1976, and amended by two addenda in 1994 and 1999, and subsequently by the Multilateral Convention (MLC). It caps the withholding tax on dividends, interest, and royalties at 15% of the source state tax, and the tax on fees for studies and technical, financial, or accounting assistance at 7.5%. It takes into account the employee's stay during the fiscal year, with a threshold of 183 days. It also includes a chapter on inheritance and another on registration and stamp duties.

This page is based on the text published by the Cameroonian Directorate General of Taxes, including amendments, the consolidated version published by the French tax authorities, which incorporates the amendments to the CML (Common Tax Law), and the French tax authorities' guidelines. Cameroonian domestic tax rates are found on our page about life in Cameroon.

A 1976 text, two amendments, the CML, no end date

The convention entered into force on July 19, 1978, following Law No. 78-658 of June 22, 1978 and Decree No. 79-768 of September 6, 1979. It applies to income paid, inheritances, deeds and claims from July 1, 1975, according to the category (Article 43).

The first amendment, dated March 31, 1994, entered into force on February 1, 1997. The second, dated October 28, 1999, has been in force since January 1, 2003. The text published by the Cameroonian administration incorporates these amendments and indicates each modified passage; it does not include the amendments to the CML (Common Monetary Law). The list of agreements of the French administration (April 29, 2026) does not mention any other amendments and, for Cameroon, is labeled "IR – S – DE": income tax, inheritance tax, registration fees.

The convention is further amended by the CML. List BOI-ANNX-000511 (April 29, 2026) indicates that, for Cameroon, the convention takes effect in France on January 1, 2023, for withholding taxes and on February 1, 2023, for other taxes. The French tax authorities publish a consolidated version of the convention as amended by the CML. This version includes, in addition to the effective dates, provisions from the preamble of the CML (Article 6), an article on the right to the benefits of the convention, which addresses cases where the granting of a benefit was one of the main objectives of an arrangement or transaction (Article 7 of the CML), and a 365-day criterion for shares whose value is derived from real estate (Article 16, paragraph 2). Read this consolidated version before applying any article.

Article 44 provides for an unlimited duration. From 1 January of the fifth year following its entry into force, each State may denounce it by giving notice before 30 June.

Three sections: income, inheritance, registration

Articles 8 to 26 deal with income taxes, articles 27 to 34A with inheritances, and articles 35 and 36 with registration and stamp duties. Administrative cooperation is addressed in articles 37 to 42.

Article 8 § 3 lists the taxes covered on each side, including income tax, corporation tax and, on the Cameroonian side, the special tax on income paid outside Cameroon.

Article 2: Where are you domiciled?

Article 2 first considers the location of the permanent home, that is, the center of vital interests. Failing that, it is the place of longest residence, then nationality. A legal entity or group is domiciled at the seat of its effective management.

This concept is that of the convention. It serves to distinguish between two states that both consider you to be domiciled in their territory. French tax domicile itself is determined by Article 4 B of the French General Tax Code (CGI), discussed on our page regarding its three criteria.

Withholding tax: 15 %, 7.5 % and the exception of copyright

These ceilings are maximums. The actual rate charged depends on the domestic law of the source state. Article 15, paragraph 3, also provides for cases where interest is exempt in the source state, particularly for the benefit of public beneficiaries; a list of these cases can be found in the text.

Salaries: 183 days, over the fiscal year

Article 22 establishes the principle that wages are taxable only in the state of residence, unless the employment is exercised in the other state. The exception in Article 22, paragraph 2, defers taxation to the state of residence when three conditions are met:

• the stay in the other State does not exceed a total of 183 days during the "tax year in question"; ;
• the employer is not domiciled in the other State; ;
• the remuneration is not deducted from the profits of a permanent establishment or fixed base which the employer has in that State.

The reference period is the fiscal year.

Pensions, real estate, capital gains

Eliminating double taxation: the tax credit under Article 26

On the French side, Article 26 § 1 a) stipulates that Cameroonian tax is not deductible from income, but entitles the taxpayer to a tax credit. For dividends and interest in particular, the credit corresponds to the tax paid in Cameroon, without exceeding the French tax due on this income. If the Cameroonian tax on interest and royalties exceeds the French tax, the taxpayer may appeal to the French tax authorities, who may allow the excess to be deducted from the French tax on other foreign-source income (Article 26 § 1 b).

On the Cameroonian side, income exclusively taxable in France is exempt from Cameroonian taxes referred to in Article 8 § 3 (Article 26 § 2 a), and income from French sources in certain articles entitles the holder to a capped tax credit (Article 26 § 2 b).

Inheritance: Articles 27 to 34 A

The administration's list is marked "S" for Cameroon. Chapter 2 of the convention governs inheritance taxes in each state:

• buildings are subject to inheritance tax only in the State where they are located (Article 28, which also regulates livestock and shares in real estate companies: read the text); ;
• Tangible movable property is located where it is at the date of death, boats and aircraft where they are registered (article 31); ;
• other assets are located in the State where the deceased was domiciled at the time of his death (Article 32); ;
• Each State exempts the other State and its local authorities for bequests made to them; paragraph 3 of Article 34 A extends these provisions to gifts.

The rules concerning business assets (Article 29), professional premises (Article 30), and the allocation of debts (Article 33) are set out in the text. For inheritances, the convention applies to deaths occurring on or after July 1, 1975.

Chapter 3 deals with registration and stamp duty. A document drawn up in one state and presented for registration in the other may be taxed there, with a credit for any duties already collected (Article 35). This page does not address the rules governing gifts inter vivos.

Non-discrimination, exchange of information, amicable procedure

Article 5 prohibits imposing a higher tax burden on nationals of another state than on nationals in the same situation. Article 37 governs the exchange of information useful for the assessment and collection of the taxes in question, while Articles 38 to 40 govern assistance in collection. Article 41 provides for an appeal to the competent authority of the state of residence; the case must be submitted to this authority within three years of the first notification of the contested measure.

Cameroon is included in the table in the annex to the draft finance law for 2027 on the exchange of information, and is not among the 11 States on the French list of non-cooperative States and territories.

Royalties, technical studies and 183 days: a numerical example (fictitious profile)

Situation. A fictitious French resident receives €20,000 in dividends, €8,000 in interest, €6,000 in patent royalties, €10,000 in fees for technical studies, and €4,000 in copyright fees from Cameroon. Employed by a French company, he also undertakes three missions to Cameroon during the year: 50, 55, and 45 days.

Issue. He wants to know the maximum tax that Cameroon can collect at source according to the convention, and whether his missions remain below the threshold of 183 days.

Strategy. He applies the ceiling of his article to each income, sets aside copyright royalties, then adds up the days of stay for the tax year.

Result. Caps: €3,000 on dividends, €1,200 on interest, €900 on royalties, and €750 on technical studies, totaling a maximum of €5,850 on €44,000 of income subject to the cap (€20,000 + €8,000 + €6,000 + €10,000). The €4,000 in royalties is taxable only in the country of residence. His assignments total 150 days: a 33-day margin. A fourth assignment of 40 days would bring the total to 190 days, 7 days above the threshold. The amounts and durations are hypothetical. The two other conditions of Article 22 remain to be examined, and the actual tax rate levied in Cameroon depends on Cameroonian law.

What changes depending on your situation

• Your home address as defined in Article 2, which is not the same as that defined in Article 4 B of the French General Tax Code (CGI).
• The nature of the income: dividend, interest, royalty, tuition fees, copyright, salary, pension.
• The number of days spent in each state during the fiscal year.
• The nature and location of your assets, and your residence at the time of death, for inheritance purposes.

The rule depends on your situation. No results are guaranteed.