The Republic of Congo (Congo-Brazzaville) taxes resident companies on worldwide income and non-resident companies only on profits earned or transactions carried out in the Republic of Congo, under the Code General des Impots administered by the Direction Generale des Impots et des Domaines. A minimum tax based on turnover applies where a company is loss-making or reports CIT below the minimum threshold.
The tax year is the calendar year for most taxpayers, with the annual minimum tax payable between March 10 and March 20 each year; standard corporate tax filing follows the calendar-year accounting period unless a different period has been approved.
Congo (Republic)'s headline corporate income tax (CIT) rate is 30%.
The headline personal income tax (PIT) rate is 40%.
The standard VAT/GST (or equivalent consumption tax) rate is 18.90% (18% + 5% surtax).
An individual has regular residence in the Republic of Congo if their principal residence is in the Republic of Congo. An individual domiciled in the Republic of Congo, whether of Congolese or foreign nationality, is taxed on worldwide income; tax treaties may exempt specific foreign-source income, though the exempt amount is still factored into determining the effective Congolese rate on the remaining taxable income. A non-domiciled individual is taxed only on Congo-source income (including income a treaty attributes to Congo) and on capital gains from disposal of certain assets; dividends, interest, and royalties from Congolese sources are typically settled via withholding tax for non-domiciled individuals. A company is resident if its registered office or principal place of business is in the Republic of Congo.
A non-resident company is treated as carrying on an economic activity in the Republic of Congo, and taxable there, where it operates through a permanent establishment, a representative without independent professional status, or where its activity results in transactions forming a complete business cycle (cycle commercial complet) within the country, a broader test than the classic fixed-place-of-business standard. Branches and foreign companies carrying out business are also subject to a deemed-distribution rule treating 70% of net branch profits as distributed and taxed at a further 15% dividend rate.
The Republic of Congo has no CFC provision. It does have transfer pricing rules and a related-party profit-shifting safeguard operating through the interest and royalty deduction caps described below, but no mechanism attributing a foreign subsidiary's undistributed profits to a Congolese resident shareholder.
Sources conflict on whether the Republic of Congo has thin capitalization rules at all. A lower-quality company-formation aggregator states thin capitalization laws "aren't officially enacted." PwC's detailed Corporate Deductions and Income Determination pages describe two concrete interest-deductibility limits that function as the country's real-world equivalent: (1) a rate cap - interest is deductible only up to the BEAC (Bank of Central African States) current-account advance rate plus three points, and only once registered capital is fully paid up; and (2) an amount cap - interest paid is deductible only up to 20% of taxable profit before deduction of the interest itself, with additional foreign-exchange compliance conditions under CEMAC rules for interest paid to non-CEMAC residents. Given the specificity of the PwC citations against the generic aggregator claim, treat the rate-cap-plus-20%-of-profit-cap structure as the operative answer rather than "no thin cap rules."
The Republic of Congo classifies entities by their domestic legal form under the Code General des Impots rather than offering an elective check-the-box system, and no ATAD2-style anti-hybrid mismatch regime addressing double-deduction or deduction-without-inclusion outcomes has been identified. As a CEMAC (Central African Economic and Monetary Community) member, the Republic of Congo's corporate tax rules operate alongside CEMAC-wide compliance conditions on cross-border interest payments to non-CEMAC residents.
No domestic FBAR-equivalent regime requires residents of the Republic of Congo to separately disclose foreign financial accounts, and the Republic of Congo is not currently a CRS participating jurisdiction, so it does not automatically exchange financial account information with foreign tax authorities under the OECD's Common Reporting Standard. US persons remain independently subject to FinCEN Form 114 (FBAR) and potentially Form 8938 regardless of the Republic of Congo's own rules.
No dedicated participation exemption regime for dividends or capital gains from a qualifying subsidiary is identified; capital gains on asset disposals, including shareholdings, are generally treated as ordinary business income and taxed at the standard 30% corporate rate rather than through a distinct exemption. Confirm current treatment of intercompany dividends and share disposals directly with the Direction Generale des Impots et des Domaines.
No general unilateral foreign tax credit mechanism is identified; relief from double taxation for Republic of Congo resident companies with foreign-source income appears to depend primarily on the CEMAC multilateral framework and the country's limited bilateral treaty network (including China, France, Italy, and Mauritius) rather than a standalone domestic FTC provision.
Limited, concentrated in the CEMAC (Central African Economic and Monetary Community) bloc plus a handful of bilateral partners. Confirmed treaty partners with reduced withholding rates on dividends include China, France, Italy, and Mauritius, alongside the CEMAC multilateral framework (Cameroon, Central African Republic, Chad, Equatorial Guinea, Gabon). A 2023 Finance Law addition imposes a 10% withholding tax on payments by a Congolese resident to a resident of any other CEMAC member state for services rendered, separate from the treaty-reduced dividend/interest/royalty rates.