On 30 October 2026, the Congo Ministry of Finance officially published the Draft Finance Law for 2027 (Projet de Loi de finances 2027), setting out the government’s fiscal policy priorities and revenue projections for the upcoming budget year. The draft law, which runs to over 200 articles, proposes comprehensive amendments to the General Tax Code (Code Général des Impôts), the Customs Code, and the Tax Procedures Code. It is the first finance bill prepared under the new IMF Extended Credit Facility arrangement approved in July 2026 and reflects the authorities’ commitment to meeting CEMAC convergence criteria, particularly the tax-to-GDP ratio target of 17% by 2027. The legislation introduces a package of tax policy measures designed to broaden the tax base, enhance progressivity, and accelerate the digital transformation of tax administration. Key proposals include a reduction in the statutory corporate income tax rate, a lowering of the VAT registration threshold, the introduction of mandatory electronic invoicing for large enterprises, and strengthened transfer pricing documentation requirements aligned with OECD BEPS Action 13. The draft also includes measures to improve tax dispute resolution and to incentivize investment in priority sectors such as agriculture, digital economy, and renewable energy. The bill will now proceed to the Council of Ministers for adoption before being submitted to Parliament for debate and enactment, with most provisions scheduled to enter into force on 1 January 2027.
Key Takeaways
- Corporate Tax Rate Reduction and Base Broadening: The draft proposes reducing the standard corporate income tax rate from 30% to 28% effective 1 January 2027, while simultaneously eliminating a range of sector-specific tax exemptions and reduced rates that have historically benefited the oil, mining, and telecommunications sectors. This base-broadening measure is expected to increase the effective tax burden on large extractive companies while providing relief to small and medium-sized enterprises. The minimum lump-sum tax (minimum forfaitaire) is also raised from 1 million XAF to 2 million XAF to ensure a minimum contribution from all corporate taxpayers.
- VAT Modernization and Digital Compliance: The legislation lowers the VAT registration threshold from 100 million XAF to 50 million XAF, bringing an estimated 15,000 additional businesses into the VAT net. It also mandates electronic invoicing for all taxpayers with annual turnover exceeding 200 million XAF, requiring real-time transmission of invoice data to the tax administration’s centralized platform (SYDONIA/E-TAX). Non-compliance will attract penalties of up to 5% of the transaction value. The move aims to reduce VAT fraud, improve audit trails, and enable pre-filled VAT returns, thereby lowering compliance costs for compliant businesses.
- Strengthened Transfer Pricing and Anti-Avoidance Rules: In line with OECD BEPS Action 13 and the CEMAC regional directive on transfer pricing, the draft introduces mandatory country-by-country reporting (CbCR) for multinational enterprise groups with consolidated group revenue exceeding 750 million EUR. It also requires master file and local file documentation for intra-group transactions above 50 million XAF annually. The tax administration is empowered to conduct transfer pricing audits with a 10-year statute of limitations, and secondary adjustments will be treated as constructive dividends subject to withholding tax. These provisions significantly raise the compliance bar for multinational companies operating in Congo and signal the government’s intent to combat profit shifting.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement
