YAOUNDÉ/PRAGUE — The income tax treaty between Cameroon and the Czech Republic has entered into force as of July 7, 2025, with provisions applicable from January 1, 2026 for withholding taxes and for other taxes on taxable periods beginning on or after that date. The agreement—signed on February 7, 2023—aims to eliminate double taxation and prevent tax evasion, providing greater certainty for cross-border investors and employers in both markets.
The in-force milestone follows a sequence of ratification steps on the Cameroonian side, including Senate approval on April 8, 2025, and Presidential ratification by decree on May 2, 2025. On the Czech side, the Ministry of Finance updated its register of double-tax agreements in September to reflect the treaty’s status. Collectively, these actions cleared the way for entry into force once the parties exchanged instruments of ratification.
What the treaty changes
For businesses and individuals with cross-border footprints, the treaty is expected to reduce juridical double taxation—for example, on dividends, interest, and royalties—by allocating taxing rights between the two countries and enabling relief mechanisms in the residence state. It also includes modern administrative cooperation provisions, such as exchange of information and mutual agreement procedures, which should help resolve disputes and improve predictability around withholding and permanent establishment issues. Specific withholding rate thresholds will depend on the final treaty text and conditions (e.g., percentage shareholding tests and beneficial ownership requirements).
Effective dates and planning window
Because application begins January 1, 2026, taxpayers have a clear window to revisit contracts, financing terms, and supply-chain arrangements that straddle year-end cut-offs. For withholding taxes, the key date is the payment date on or after January 1, 2026; for other taxes, the treaty applies to taxable periods beginning on or after January 1, 2026. Companies should align certificate-of-residence processes, confirm beneficial ownership standards for treaty claims, and update withholding and reporting systems in both jurisdictions.
Who benefits
Exporters, engineering and construction contractors, and service providers operating between Cameroon and the Czech Republic stand to benefit most, given the reduction in tax frictions and the availability of dispute-resolution channels. Financial flows—such as intercompany dividends and interest—may see lower effective tax costs where treaty conditions are met, while royalty streams can gain clarity on source-country taxing rights. The treaty is also relevant to individuals (expatriates, cross-posted staff), whose residence/sourcing outcomes and relief mechanisms are now anchored in a bilateral framework rather than solely in domestic law.
Compliance watch-outs
Treaty relief is not automatic. Expect stricter documentation around treaty eligibility, including evidence of beneficial ownership and substantive activity where reduced rates are claimed. Businesses should also map the interaction between treaty relief and domestic withholding rules in both countries, noting Cameroon’s default rates under domestic law and the Czech Republic’s domestic WHT framework where no treaty applies or where conditions are unmet.
