Gabon's 2011 Finance Act introduced a special tax regime for group companies. The benefit of this regime is subject firstly to compliance with certain conditions relating to the legal and tax status of the company and secondly to the performance of certain activities defined by law. A group of companies is taken to mean a group of companies subject to equivalent foreign tax in whatever form, linked together by direct or indirect capital links of at least 50% and which enable one or more of them...

International trade has experienced spectacular growth in recent decades, supported by a broad movement towards economic globalization and rapid progress in the means of communication. As customs barriers have been dismantled, we have witnessed the birth of groups of companies which have gradually "internationalised" in order to take advantage of competitive and regulatory advantages, thus increasing the flow of intra-group transactions. Like other transactions, those carried out by entities ...