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12.4.1. Main Rules

Definition of Related Parties

For the purpose of transfer pricing, related parties are generally defined as a resident company controlled by or controlling a non-resident entity. Two parties are also deemed to be related if they are both controlled by a third party.  Dependency or control is deemed to exist where:

  • 25% of the share capital of one enterprise is held directly or by proxy by the other enterprise or actually exercises decision-making powers in the other; or
  • under the conditions defined above, both parties are placed under the control of the same enterprise or person.

Transfer Pricing Methods

The Cameroon tax authorities required the use of the following three transfer pricing methods:

  • Comparable uncontrolled price (CUP) method
  • Resale price method
  • Cost-plus method

Use and Availability of Comparables

No specific guidance is included in Cameroon's transfer pricing rules in regard to the use and availability of comparables aside from allowing their use to substantiate the arm's length nature of transactions with related parties.