CAMEROON
I.LEGAL AND TAX REGIME OF THE MINING SECTOR IN CAMEROON
In Cameroon, the mining sector is regulated by a set of laws and regulations that establish the legal and fiscal framework for the exploration, exploitation and marketing of mineral resources.
Here are some key elements of the legal and tax regime of the mining sector in Cameroon, although the details may change. It is always recommended to consult the most recent legal texts and seek specialist legal advice from the experts at EMPC Africa who are at your disposal.
I.1. Legal regime :
- Mining Code: The Mining Code of Cameroon is the main law that governs mining activities in the country. It sets the conditions for granting mining titles, the rights and obligations of holders, as well as the procedures for obtaining authorizations. The most recent Code is No. 2023/014 of December 19, 2023.
- Mining agreements: Mining companies operating in Cameroon can sign mining agreements with the government. These agreements specify the conditions for exploration and exploitation, royalties, environmental obligations, and other aspects related to mining activity.
- Société Nationale des Mines (SONAMINES): SONAMINES is a publicly owned company with the State as the sole shareholder. Its mission is to develop and promote the mining sector in Cameroon, with the exception of hydrocarbons and quarry substances, and to manage the interests of the State in this area.

Tax REGIME
Mining companies in Cameroon are subject to both common law taxation and specific mining taxation.
- Royalties: Mining companies in Cameroon are generally required to pay royalties on mining production. These royalties can be calculated based on the value of the minerals extracted.
- Corporate Income Tax (CIT): Mining companies are subject to Corporate income Tax, the rate of which may vary depending on the legal provisions in force.
- State participation: The State can hold a direct stake in mining projects, generally in the form of a participation in the capital: 10% free carried shares and 25% optional for valuable consideration.
- Fiscal Stabilization: Mining agreements typically include legal and fiscal stabilization clauses to protect investments from unforeseen changes in local legislation.
II.LEGAL AND TAX REGIME OF THE UPSTREAM OIL SECTOR IN CAMEROON
Oil exploration began in Cameroon in 1947. The first research permit for hydrocarbons was granted on April 16, 1952, in the Douala basin. Cameroon effectively became an oil producer in 1977 following the start of production from the “Kolé” field.
From 1980 to 1986, the country experienced its most active period in terms of oil exploration with a production level of 186,000 barrels/day in 1985. Oil activities continued in two of the three major sedimentary basins in the country, namely, the Rio Del Rey basin and the Douala-Kribi-Campo basin.
Seventeen oil companies are active in oil exploration or production in Cameroon, either alone or as part of consortiums set up for this purpose.
II.1 Legal regime:
The upstream sector is governed by the main texts listed below, to which other specific texts not listed and non-contrary common law texts must be added:
- The Petroleum Code (published in 1999) replaced by Law No. 2019/008 of April 25, 2019 establishing the new Petroleum Code of Cameroon.
- The petroleum decree: In Cameroon, Presidential Decree No. 2023/232 of May 4, 2023 establishes the terms of application of Law No. 2029/008 of April 25, 2019 on the petroleum Code.
- Former conventions of establishment
- Exploration and Production Contracts: Oil companies operating in Cameroon generally sign exploration and production contracts with the government. These contracts set out the specific terms and conditions for each project.
II.2 THE NATIONAL HYDROCARBONS CORPORATION (SNH)
II.3 Tax regime
- Corporate Income Tax (CIT): Companies operating in the upstream oil sector in Cameroon are subject to Corporate Income Tax, the rate of which may vary depending on contractual provisions.
- Specific Royalties and Taxes: Oil companies pay specific royalties and taxes based on production and other criteria defined by legislation.
- State Participation: The state may hold a direct stake in oil projects, often in the form of equity or financial participation.
- Fiscal Stabilization: Petroleum contracts typically include legal and tax stabilization clauses to protect investments from unforeseen changes in local law.
It is important to note that specific tax and legal terms may vary depending on individual contracts between the government and oil companies..
The parties involved often negotiate specific terms for each project, and these terms are recorded in exploration and production contracts. For up-to-date and accurate information, it is recommended to consult the relevant legal documents and seek specialist legal and tax advice from our firm working in Cameroon.
III.Gas sector regime
III.1 Legal regime
In Cameroon, the Gas Code governs the downstream gas sector which includes in particular the activities of transport, distribution, transformation, storage, import, export and sale of natural gas and its by-products on the national territory. .
The law aims to promote the development of the downstream gas sector in Cameroon. As such, it aims in particular to: establish a legal framework conducive to the development of gas resources; create a favourable environment for the entry of national and foreign private investors into the gas sector; set out the principles within which regulation will be carried out; guarantee the safety of installations and protection of the environment.
The State organizes the rules which will govern its regulation and its intervention in the sector. The law introduces planning in the development of gas resources.
III.2 Tax regime
IV. Legal and tax regime for public private partnership contracts in Cameroon
IV.1. Legal regime :
- Law of July 25, 2023 establishing the regime of public-private partnership (PPP) contracts: The law on PPPs in Cameroon defines the general principles and procedures applicable to public-private partnerships. It specifies the conditions for awarding, managing and executing these contracts.
- Public Contracts Regulatory Agency (ARMP): The ARMP plays a role in the PPP contract award process by supervising the tender procedures and ensuring transparency and fairness in the process. .
- PPP contracts: PPP contracts are concluded between the public entity and the private partner. They specify the obligations, rights, responsibilities, financing arrangements, and risk-sharing mechanisms between the parties.
IV.2. Tax regime ( see article 18 of the law of July 25, 2023:
- Tax Incentives: PPP contracts may benefit from specific tax incentives, such as tax reductions or tax benefits, to encourage private sector investment in infrastructure projects.
- Tax treatment of income: Income generated from PPP projects may be subject to specific tax treatment, and the terms are often defined in individual contracts.
- Tax Stabilization: Some PPP contracts may include tax stabilization clauses to protect private investors against unexpected changes in tax law.
It is essential to note that the specific terms of PPP contracts may vary depending on the nature of the project, the parties involved and other factors. Investors and public entities involved in PPP projects should carefully review the terms of contracts, regulations in force and consult expert legal advisors to ensure compliance with legislation and protection of the interests of the parties involved.