angola-ctg24

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• 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

The contractual regime applies to investment projects that amount to at least USD10 million and that creates a minimum of 50 jobs for Angolan nationals. The benefits vary in accordance with the specifics of the investment and include, among others, the following:

• Reduction of property tax up to 15 years

• Tax credits up to 50% of the investment value to be recovered during a period of 10 years

• Reduction of corporate income tax up to 15 years

• Deferral of tax payments

Withholding tax. In general, resident and foreign companies are subject to a withholding tax rate of 6.5%.

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 intermediation 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 provider 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

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 financial, 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.

These rates may vary depending on the industry sector.

Relief for losses. Companies may carry forward tax losses for five years. 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 companies 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.

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

Companies owning a prospecting license

Exploration companies

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)

USD0.15 per barrel

USD100,000 a year

USD300,000 a year

Property

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

Special contribution on foreign-exchange operations; the 2024 State Budget Law approved a special contribution on foreign-exchange operations, which applies to transfers made under contracts for the provision of services, technical assistance, consulting and management, as well as to capital operations and unilateral transfers; the contribution will be in force during 2024; certain payments are exempt from this contribution, including, among others, dividends, interest and capital reimbursements

E. Miscellaneous matters

Foreign-exchange controls. The BNA supervises foreign-exchange operations, which generally must be controlled by commercial

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