Equatorial Guinea taxes residents on worldwide income and non-residents on Equatorial Guinea-source income only. Equatorial Guinea operates a self-assessment system for corporate tax, with the domestic tax authority conducting post-filing review.
Equatorial Guinea's tax year is the calendar year.
Equatorial Guinea's headline corporate income tax (CIT) rate is 25%.
The headline personal income tax (PIT) rate is 25%.
The standard VAT/GST (or equivalent consumption tax) rate is 15%.
A commercial entity operating in Equatorial Guinea for more than 3 months in one calendar year, or for 6 months within a 2-year period, is considered resident. Resident companies are subject to CIT on worldwide income, though PwC notes that in practice this is tolerated as applying only to Equatorial Guinea-related activities - consistent with the territorial principle described below. Companies registered in Equatorial Guinea carrying on business outside the country are, in principle, not subject to Equatorial Guinea corporate tax on those foreign profits.
A non-Equatorial Guinea-resident entity has a Equatorial Guinea permanent establishment through a fixed place of business or a dependent agent habitually concluding contracts in Equatorial Guinea on the entity's behalf, following the OECD Model Treaty definition as applied under Equatorial Guinea's domestic law and any applicable tax treaty.
No CFC-style attribution provision exists in Equatorial Guinea's new General Tax Code (Law No. 1/2024, in force since 19 November 2024, replacing the prior code). The new code strengthens strict transfer-pricing controls on related-party transactions ("un controle strict des prix de transfert entre les transactions entre parties liees") as one of its headline new anti-avoidance features, alongside taxing dividends at permanent establishments and new source withholding on movable/immovable income - but does not introduce a CFC-style attribution mechanism. This is consistent with Equatorial Guinea's own corporate tax system taxing outbound activity on a territorial basis (foreign profits of EG-registered companies generally fall outside the EG tax base), which structurally reduces the need for a CFC-style anti-deferral rule in the way a worldwide-taxation system would require one.
Equatorial Guinea has no formal thin capitalization ratio, but real, specific limits on interest deductibility apply. Interest paid to shareholders for amounts advanced beyond their capital contribution is non-deductible to the extent it exceeds the central bank's advance interest rate (currently 3.25%); separately, interest on the portion of shareholder loans exceeding one-half of capital stock is non-deductible where the shareholder participates in company management.
Equatorial Guinea does not use an elective check-the-box classification system; entity classification generally follows the entity's actual legal characteristics under the French-derived legal tradition shared across the region. Equatorial Guinea does not have a comprehensive ATAD2-style anti-hybrid regime.
No foreign bank account or foreign financial asset reporting regime exists requiring residents to separately disclose foreign accounts; foreign income is reported through the standard annual tax return.
Equatorial Guinea does not provide a broad participation exemption for foreign dividends in the European sense, consistent with the transfer-pricing-focused (rather than exemption-focused) anti-avoidance framework already confirmed elsewhere on this page; relief from double taxation is available primarily through Equatorial Guinea's foreign tax credit system where one exists.
Per PwC's Equatorial Guinea tax summary, there is no foreign tax credit in Equatorial Guinea - relief from double taxation is limited to the CEMAC treaty framework described below.
Equatorial Guinea has a double tax treaty with the member states of CEMAC collectively (alongside Cameroon, Chad, Central African Republic, Republic of Congo, and Gabon). CEMAC-resident entities and individuals benefit from a lower maximum 10% withholding tax rate versus the general 15% (dividends/interest) or 10% (royalties, non-CEMAC) rates applying to other non-residents. No broader bilateral double tax treaty network beyond CEMAC is identified in available sources; Equatorial Guinea does maintain a separate 1980 Treaty of Friendship and Cooperation with Spain, but this is a diplomatic/cooperation instrument rather than a tax treaty.