Angola - New Personal Income Tax Code (“IRPS”)

In brief

The proposal for the new Personal Income Tax Code (“IRPS”) was put out for public consultation on 1 April 2025, with the aim of collecting contributions from the different social, economic and professional partners, which will run until 30 April 2025.

In detail

This proposal aims to create a single tax covering all income of individuals, replacing the current model of taxation of personal income based on different legislation levied on different types of income, such as the Employment Income Tax Code (“IRT”), the Capital Investment Tax Code (CIAC”) and the Property Tax Code (in the part relating to property income). 

The proposed IRPS Code foresees a profound change in the taxation of individuals in Angola. We highlight the following most relevant aspects: 

1) A model of taxation of worldwide income (all income, regardless of the source) is adopted for tax residents in Angola and of territorial-based taxation (income from Angolan sources) for non-residents, replacing the current territorial-based taxation applicable to all taxpayers. 

2) In general, tax residency in Angola will be assessed based on the individual's stay in Angolan territory, and it is sufficient to remain there for more than 90 days, consecutive or interpolated, in any 12-month period starting or ending in the year in question, to qualify as a tax resident. The members of the household are always considered to be tax residents, if any of the taxpayers is a tax resident.  

3) IRPS will be levied on various types of income, divided into five categories: 

• Category A: employment income; 
• Category B: business and professional income; 
• Category C: investment income; 
• Category D: rental income; 
• Category E: asset increases, including capital gains. 

There is no provision for taxation on pension income.

4) As a rule, the tax due by tax resident taxpayers will be determined by aggregating all income earned (“aggregation”), which will be subject to marginal rates of up to 25% (with the exception of investment income from capital, subject to withholding tax at final rates of 10% or 15%, and exempt income), with the tax withheld at source when paying income being considered as a payment on account of the final tax. 

5) As a rule, taxpayers will be required to submit an annual income tax return electronically, an obligation which they will only be exempt from if they have only received category A income paid by a single employer (in which case the withholdings made by this entity are definitive in nature). 

6) The IRPS withholding tax rates will be 6.5% (business and professional income, except if obtained by non-residents and not attributable to a permanent establishment in Angolan territory, in which case 10% will apply), 10% or 15% (investment income), 25% (rental income) and 10% (most asset increases, except those unjustified, subject to 25%). 

7) When calculating the tax due, it is possible to deduct health and education expenses incurred by the income holder and his/her dependents, carried out in Angolan territory and duly documented, with specific limits, which vary according to the number of dependents in the household. 

8) Resident taxpayers who obtain income from foreign sources in countries with which Angola has entered into a double tax treaty will be entitled to a tax credit for international double taxation.

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