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Luanda Angola
Principal Tax Contacts and Business Tax Advisory
Milton Chantre Melo +244 227-280-461 Mobile: +244 936-725-788 Email: milton.melo@pt.ey.com
Rui Henriques +244 227-280-461 Mobile: +351 937-912-028 Email: rui.henriques@pt.ey.com
International Tax and Transaction Services – Transaction Tax Advisory Paulo Mendonça +351 217-912-045 (resident in Lisbon) Mobile: +351 966-867-735 Email: paulo.mendonca@pt.ey.com
A. At a glance
Corporate Income Tax Rate (%) 25 (a)(b)
Capital Gains Tax Rate (%) 25 (c) Branch Tax Rate (%) 25 (a)(b)
Withholding Tax (%)
Dividends 10 (d)
Interest 5/10/15 (e)
Royalties 10
Payments for Services 6.5 (f)
Branch Remittance Tax 10 Net Operating Losses (Years)
Carryback 0
Carryforward 5 (g)
(a) The standard Corporate Income Tax rate is 25%. Income from certain activi ties, such as agriculture, forestry and cattle raising, is subject to tax at a rate of 10%. National oil and gas companies, banks, insurance companies and telecom operators are subject to tax at a rate of 35%.
(b) Tax exemptions or tax reductions are available under the Private Investment Law as well as specific legislation for micro, small- and medium-sized com panies. For details, see Section B.
(c) Gains derived from the sale of securities that are not subject to Corporate Income Tax or Personal Income Tax are subject to Investment Income Tax at a rate of 10%. If such gains are derived from treasury bills, treasury bonds and titles issued by the Angolan Central Bank (Banco Nacional de Angola, or BNA) with a maturity of at least three years or from shares of listed compa nies, a 50% tax relief may apply.
(d) Certain dividends are exempt from tax (see Section B). A 5% rate applies to dividends paid by listed companies during a five-year period beginning on 19 November 2014.
(e) In general, interest is subject to a 15% rate. However, certain interest, such as interest on shareholders loans, corporate bonds, bank deposits, treasury bills, treasury bonds and titles issued by the BNA is subject to a 10% rate. Interest on treasury bills and treasury bonds and titles issued by the BNA is subject to a reduced rate of 5% if the maturity is at least three years.
(f) Some exceptions are available. A general withholding tax rate of 15% applies to payments for services abroad. However, as per the 2022 State Budget, this rate will remain at 6.5% on service payments made to foreign service provid ers. An exception may be available through double tax treaties. (g) Mining companies may carry forward losses for seven years, up to a limit of 50% of the turnover.
B. Taxes on corporate income and gains
Corporate Income Tax. Companies carrying out industrial and commercial activities in Angola are subject to Corporate Income Tax (Imposto Industrial).
An Angolan company, which is a company that has its head office or effective place of management and control in Angola, is sub ject to Corporate Income Tax on its worldwide profits.
Foreign entities with a permanent establishment in Angola are subject to Corporate Income Tax only on profits allocated to the Angolan permanent establishment. The tax law provides a force of attraction principle for permanent establishments.
All companies, regardless of whether they have a permanent es tablishment in Angola, are subject to Corporate Income Withholding Tax on services provided to entities established in Angola for tax purposes.
Corporate Income Tax taxpayers are classified into the following two regimes:
• General Regime: applicable to all companies in general
• Simplified Regime: applicable to companies that are not subject to value-added tax
Rates of corporate tax. The standard Corporate Income Tax rate is 25%.
Income from certain activities, such as agriculture, forestry and cattle raising, is subject to a reduced tax rate of 10%. National oil companies, banks, insurance companies and telecom operators are subject to tax at a rate of 35%.
A Private Investment Law was approved as Law No. 10/18 of 26 June 2018. This law provides that no minimum amount is re quired for foreign or domestic (national) investments.
Benefits and incentives vary according to the type of regime to which the investment project is subject and the investment zones, among other factors.
The standard regime provides, among other benefits, a reduction of 20% on the final and provisional assessment rates for Corporate Income Tax purposes, and a 25% reduction on the Investment Income Tax rate on dividends. Both benefits have a duration of two years.
The special regime applies to investment projects in priority sec tors. The benefits vary in accordance with the respective loca tion, and include, among others, the following:
• Reduction of the Corporate Income Tax rate by a percentage ranging from 20% to 80%, for a period varying from two to eight years
• Fifty percent increase of the depreciation rates for an eight-year period
• Reduction of the Investment Income Tax rate on dividends and profits distributed or remitted, by a percentage ranging from 25% and 80%, for a period from two to eight years
The following are the priority sectors:
• Education, technical and professional training, higher educa tion, scientific research and innovation
• Agriculture, food and agro-industry
• Specialized health services
• Reforestation, industrial transformation of forest resources and forestry
• Textiles, clothing and footwear
• Hotel and tourism
• Construction, public works, telecommunications and information technology
• Airport and railway infrastructure
• Production and distribution of electricity
• Sanitation and solid waste treatment
The following are the four investment zones:
• Zone A: Province of Luanda, the capital municipalities of the Benguela and Huíla provinces, and the municipality of Lobito
• Zone B: Provinces of Bié, Bengo, Cuanza-Norte, Cuanza-Sul, Huambo, Namibe and the other municipalities of Benguela and Huíla
• Zone C: Provinces of Cuando Cubango, Cunene, Lunda-Norte, Luanda-Sul, Malanje, Moxico, Uíge and Zaire
• Zone D: Province of Cabinda
Withholding tax. In general, resident companies are subject to a withholding tax rate of 6.5%, while foreign companies are subject to a withholding tax rate of 15%. An exception was introduced in the 2022 State Budget for income obtained by nonresident service providers, which will be subject to a withholding tax at a 6.5% rate during 2022.
The following services are excluded from withholding tax:
• Teaching and similar services
• Health services
• Passenger transportation services
• Lease of machinery and equipment subject to Investment Income Tax
A similar exclusion applies to financial and insurance intermedia tion services, hotel and similar services, and telecommunication services, if the service provider has a taxable presence in Angola. For local service providers, withholding tax does not apply to documented recharges between related parties. Payments for raw materials, parts and other materials used on services provided are also excluded from the withholding tax base if the service pro vider has a taxable presence in Angola.
The payer must withhold the tax from each payment and remit the withholding tax to the Angolan Revenue Authority. The tax withheld is considered to be an advance Corporate Income Tax payment if the service provider has a residence, head office or permanent establishment in Angola. Excess withholding tax can be carried forward if duly recognized by the Angolan Revenue Authority. If the tax is withheld from a nonresident entity service
provider with no permanent establishment in Angola, these values are considered to be final.
Special taxation regimes. Income from oil and gas extraction is subject to Petroleum Income Tax at a total rate of 50% (under production-sharing agreements) or 65.75% (under other types of joint ventures). Angolan companies benefit from a reduced Petroleum Income Tax rate equivalent to that of Corporate Income Tax. In addition, companies engaged in exploration and production of petroleum oil, gas and similar products must pay Petroleum Production Tax at a total rate of 20%. Petroleum Transaction Tax and a Surface Surcharge may also be levied at rates of 70% and USD300 per square kilometer, respectively. Petroleum Production Tax and Petroleum Transaction Tax are not payable under production-sharing agreements.
Contracts, such as production-sharing agreements, between oil and gas companies and the Angolan government generally over ride the Petroleum Production Tax and Petroleum Transaction Tax and may set forth different taxes and applicable rates.
Additional taxes and charges apply within the oil and gas and mining industries. Also, specific tax rules apply to the liquefied natural gas project, including withholding tax exemptions on certain interest, dividends, royalties and services income.
Capital gains. Capital gains on profits derived from the sale of fixed assets are subject to Corporate Income Tax at the regular tax rate of 30%. Capital gains derived from the disposal of shares or other instruments generating Investment Income Tax (not tax able for Corporate Income Tax or Personal Income Tax purpos es) are subject to Investment Income Tax at a 10% rate. However, a 50% relief is available for capital gains derived from the disposal of listed shares or from corporate bonds, other secu rities, treasury bonds, treasury bills and BNA securities, if they are negotiated in a regulated market and if their maturity is of at least three years.
Administration. The tax year is the calendar year.
All companies engaging in activities in Angola must register with the tax department to obtain a taxpayer number.
Companies, including foreign companies with a permanent es tablishment in Angola, must file an annual Corporate Income Tax return, together with their financial statements and other documentation, by the end of April (Simplified Regime) or May (General Regime) of the following year.
Penalties are imposed for a failure to file tax returns and other required documents. If, on the final assessment, the tax authorities determine that a further payment is required, in addition to the unpaid tax, a penalty of 25% and compensatory interest, assessed daily at a 1% monthly rate, will be due. Late payment interest also applies to nonpayment of the above tax debt.
Dividends. Companies are not subject to Corporate Income Tax on the gross amount of dividends received if the dividends have been subject to Investment Income Tax.
A 10% Investment Income Tax, which is withheld at source, is imposed on dividends.
The Investment Income Tax Code provides a participation ex emption regime that sets an exemption whenever Angolan parent companies from Angolan subsidiaries subject to Corporate Income Tax hold a minimum of 25% of the share capital of the company distribution of the dividends, and this is held for one year.
Foreign tax relief. In general, no relief is granted for foreign taxes paid by Angolan taxpayers.
C. Determination of taxable income
General. Taxable income is the income reported in companies’ financial statements, subject to certain adjustments. Expenses considered indispensable in the production of income and the maintenance of a production unit are deductible. The following expenses, among others, are not deductible and are added back to taxable income for Corporate Income Tax purposes:
• Provisions and depreciation deemed to be unlawful, excessive or unauthorized by the tax authorities
• Bad or irrecoverable debts
• Interest on shareholders loans, on the component exceeding the average annual rate published by the BNA
• Personal Income Tax, social security contributions by the em ployee, Investment Income Tax and Property Tax
• Costs associated with rented property, considered in the com putation of Property Tax
• Costs related to previous years
• Donations not covered by the Law of Patronage
• Non-documented expenses and improperly documented expenses
• Confidential expenses (an expense is considered a confidential expense if no valid documentation legally supports the expense and if its nature, function or origin are not materially justifiable)
• Fines and penalties
• Unrealized foreign-exchange losses
Unrealized exchange gains are not part of taxable income.
Rental of immovable property income subject to Property Tax and income subject to Investment Income Tax are excluded from the Corporate Income Tax base.
Stand-alone tax for certain expenses that are nondeductible for Corporate Income Tax purposes. Certain expenses that are nonde ductible for Corporate Income Tax purposes are subject to a stand-alone tax. This tax applies currently to confidential ex penses (30%, or 50% in certain situations) and donations not made in accordance with the Law of Patronage (15%).
Inventories. Inventories may be valued by any currently accept able method provided that the method is consistently applied and is based on documented purchase prices.
Provisions. Costs for provisions for the following items are deductible for Corporate Income Tax purposes:
• Bad debts up to 4% (for the annual allowance regarding the booking of a new provision or the increasing of a previous balance) or 10% (accumulated balance) of clients’ receivables, if,
among other requirements, such credits have been claimed and are due for more than six months and if steps to collect the claim have been undertaken
• Provisions imposed by the public regulatory authorities of finan cial, insurance and gambling businesses
• Litigation processes regarding facts underlying the litigation claims that would represent costs of that year
• Depreciation in the value of inventory, provided that it does not exceed 0.5% to 3% in the current year (depending on the nature of the activity), up to a limit that can vary between 2.5% and 12% of the value of the inventory
Tax depreciation. Depreciation rates are provided in the law. The following are some of the applicable rates.
Asset Rate (%)
Vehicles 16.67 to 25
Office buildings 4
Industrial buildings 4 or 6
Machinery, equipment and devices
12.5 to 33.33
Furniture 8.33 to 50
These rates may vary depending on the industry sector.
Relief for losses. Companies may carry forward tax losses for five years, starting from 2017. This period is increased to seven years for mining companies (up to a limit of 50% of the turnover). No carryback is allowed.
Groups of companies. The Large Taxpayers Statute establishes that Angolan Large Taxpayers that are integrated in a group of com panies may be taxed on the sum of the taxable results obtained by the entities included in the group. For such purpose, a special request through a specific official form must be submitted to the tax authorities by the end of February of the tax year for which the application of this special regime is requested. The Head of the Large Taxpayer’s Office must expressly approve this request and, accordingly, the application of the group taxation regime.
D. Other significant taxes
The following table summarizes other significant taxes.
Nature of tax Rate
Value-added tax
General rate 14%
Reduced rates 5%/7%
Excise duties; levied on specific goods provided in Angola or imported into Angola (included in the Excise Duty Code, contained in Law 8/19 of April 24)
2% to 5% Training levy, on oil and gas exploration and production companies and their subcontractors
Production companies and companies engaged in refining and processing of petroleum USD0.15 per barrel Companies owning a prospecting license USD100,000 a year
Exploration companies
USD300,000 a year
Nature of tax Rate
Subcontractors under a contract with a term exceeding one year (levied on annual gross income) and entities engaged in the storage, transport, distribution and trading of petroleum (levied on revenue derived from such activities) 0.5%
Stamp duty
On the acquisition of real estate 0.3%
On leasing and subleasing of real estate 0.1%/0.4%
On company’s share capital 0.1%
On guarantees 0.1% to 0.3%
On financing 0.1% to 0.5%
On financial leasing of real estate 0.3%
On leasing of movable property 0.4% Custom duties on imports 2% to 70% Customs emoluments 2%
Property Tax
Levied on 60% of the gross rent 25%
Levied on property transfers (levied on transaction value) 2%
Social security contributions, on salaries and additional remuneration; the contributions are not payable by expatriates working in Angola if they make contributions to the social security scheme or a similar scheme in their home countries; paid by Employer 8% Employee 3%
E. Miscellaneous matters
Foreign-exchange controls. The BNA supervises foreign-exchange operations, which generally must be controlled by commercial banks that usually act as intermediaries of companies to obtain clearance from the BNA.
BNA issued Bank Order No. 2/20 of 9 January 2020. This order sets out new foreign-exchange procedures to be adopted with respect to current invisible operations carried out by resident companies. The order eliminates the obligation for prior approval of current invisible operations, regardless of their respective amount. Commercial banks are responsible for the evaluation and validation of all current invisible operations, registering them at the Integrated Foreign Exchange Operations System (SINOC) before their execution.
In general, repatriation of profits is allowed for approved foreigninvestment projects if certain requirements are met.
The oil and gas sector is subject to a specific foreign-exchange control regime, which aims primarily to establish uniform treat ment in this sector by replacing the multiple exchange regimes that have been applied to oil and gas upstream companies operat ing in Angola, thereby providing fair treatment to all investors.
These foreign-exchange control rules cover the trade of goods, current invisible operations (according to the Angolan National
Bank Instructive, these operations are services, royalties, interest, travel costs and salaries) and capital investments.
For purposes of the rules, exchange operations encompass the following:
• Purchase and sale of foreign currency
• Opening of foreign currency bank accounts in Angola by resident or nonresident entities and the transactions carried out through these bank accounts
• Opening of national currency bank accounts in Angola by non resident entities and the transactions carried out through these bank accounts
• Settlement of all transactions of goods, current invisible opera tions and capital movements
Thin-capitalization rules. No thin-capitalization rules are in effect in Angola. However, the deductibility of interest costs with respect to shareholders’ loans is limited for Corporate Income Tax purposes. Costs are deductible up to the average annual rate published by the BNA.
Anti-avoidance legislation. The arm’s-length principle applies in Angola. Consequently, the tax authorities may adjust the taxable income derived from transactions between related parties.
Related-party transactions. The Large Taxpayers Statute contains specific rules governing “special relations” between taxpayers, which entered into force in October 2013. Under this regime, a special relationship is deemed to occur if one entity exercises, directly or indirectly, a significant influence on the management decisions of another entity. The law also establishes that a taxpayer that has annual turnover exceeding AOA7 billion at the date of closing the accounts must prepare and submit a transfer-pricing file to the Angolan tax authorities. This transferpricing file, which must be prepared on an annual basis, must detail the relationships and prices established by the taxpayers with the companies and entities with which they have “special relations.” The transfer-pricing file must be submitted by the end of the sixth month following the year-end to which the file relates. With respect to the economic analysis of the transactions, the new regime provides for the application of the following methods only:
• Comparable uncontrolled price method
• Resale-minus method
• Cost-plus method
Invoice requirements. Requirements are imposed with respect to the keeping and archiving of invoices or equivalent documents by individuals or legal entities with their domicile, registered office, effective management or permanent establishment in Angola. Invoices should be issued through certified software, for certain taxpayers.
Standard Audit File for Tax reporting. Certain companies are re quired to file, on a monthly basis, a Standard Audit File for Tax (SAF-T). This file follows a standardized template, in an xml format, to be extracted from the accounting software, which must be duly certified. Currently, the monthly reporting corresponds to the sales and purchases carried out in the preceding month.
Tax-neutrality regime for mergers and demergers. A tax-neutrality regime for mergers and demergers applies for Corporate Income Tax purposes at the level of the merged or spun-off companies, but not at the level of the respective shareholders.
F. Tax treaties
Angola has double tax treaties in force with Portugal and the United Arab Emirates, which may allow for the potential reduc tion of the tax rates applicable to income paid to the relevant countries.