ATAF-CEMAC Workshop on Transfer Pricing: Towards a New Era of Tax Cooperation in Central Africa

  • rpitjeng@ataftax.org
  • 31 Mar 2026
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As part of ongoing efforts by ATAF to strengthen its support to French speaking African countries, ATAF and CEMAC organized a joint workshop in Douala from March 23 to 27, 2026. The workshop brought together 17 participants representing the tax administrations of Chad, the Central African Republic, Cameroon, Gabon, Equatorial Guinea, and the Republic of the Congo.

Dr. Nyah Zebong facilitated the five (5) day Seminar that focused on strengthening the capacity of CEMAC member states’ tax administrations to audit MNE’s, notably on transfer pricing but also with respect to other international tax issues. It also aimed to encourage the sharing of experiences among participating countries, to reinforce the existing legal frameworks on transfer pricing. The Douala workshop constitutes a first step towards a broader collaboration framework between ATAF and the CEMAC Commission, aimed at capacitating the tax administrations of the region with critical skills in this area and establishing a regional transfer pricing task team within CEMAC.

Discussions during the engagement included examining: (1) cross-border avoidance schemes -permanent establishments, transfer pricing, thin capitalization, intra-group debt and interest, treaty shopping); (2) transfer pricing -ALP, comparability analysis and functional analysis, transfer pricing methods, documentation.

An important part of the workshop included presenting to all participants, ATAF’s suggested approach to drafting Transfer Pricing legislation and regulations and using this as the basis for performing a diagnostic analysis of existing legal frameworks. This includes CEMACs regional directive on transfer pricing, and the tax legislations/regulations of all six (6) member countries.

Discussions during the workshop revealed major gaps in transfer pricing regimes within CEMAC comity of states and marked an important step in strengthening tax cooperation on the issue between ATAF and CEMAC, and among CEMAC countries. The project, which is funded under the Multi-donor Agreement (MDA) between ATAF, the European Union, Finland and BMZ supported by GIZ, is a major milestone in the provision of impactful technical assistance by ATAF to these countries.

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