Angola – 2024 State Budget Law
03/01/24
In brief
Law 15/23 of 29 December 2023 approved the General State Budget for 2024 (OGE 2024). This diploma entered into force on 1 January 2024.
In detail
Law 15/23 of 29 December 2023 approved the General State Budget for 2024 (OGE 2024). This diploma entered into force on 1 January 2024.
Among the various tax measures included in the diploma, we highlight the following:
- Introduction of the Extraordinary Levy on Foreign Exchange Operations (“Contribuição Especial sobre Operações Cambiais” or “CEOC”). It shall be due on transfers related with agreements for the rendering of services, technical assistance, consulting and management, capital operations and unilateral transactions.
- Payments of health and education expenses are excluded from CEOC as long as they are made directly to the bank accounts of health and education institutions as well as transfers of dividends, reimbursement of borrowed capital and associated interest.
- The CEOC will apply to natural persons or companies domiciled or headquartered in Angolan territory that request transfers of funds from a financial institution for payments subject to this extraordinary levy.
- The applicable rate is 10% for corporate entities and 2.5% for individuals. It applies to the value of the transfer.
- Exemptions apply to i) the State and any of its bodies, establishments and organizations, except public institutes and companies; and ii) diamond companies and oil companies.
- Financial institutions shall guarantee the assessment and settlement of the CEOC otherwise incurring fines in an amount corresponding to the levy. Other sanctions provided for in the General Tax Code shall also apply.
OGE 2024 reproduces the set of rules contained in the 2023 State Budget law (OGE 2023), with the exception of the provision introduced on electronic auctions, which establishes that auctions are carried out by applying the rules defined in the Customs Code.
Authorized Economic Operators, certified as Official Brokers and Freight Forwarders, are granted the following benefits:
1. Importers and exporters
i) Possibility of paying custom duties in installments.
ii) 60-day deadline for presenting the Declaration of Exclusivity Commitment on goods imported into the Production Sector.
iii) Exemption from presenting a guarantee in the customs clearance process; and the possibility of customs clearance of goods with deferral of payment of duties and other customs duties taxes due.
2. Official Brokers and Freight Forwarders
i) Reduction in the number of physical and documentary inspections.
ii) Ppriority treatment if selected for physical and documentary inspections; and
iii) Eexemption from presenting a guarantee in transit processes.
OGE 2024 replicates a set of gaming taxation rules provided for in the OGE 2023 and extends the banked games regime to automatic machines, with some specificities.
Employment income is exempt from Personal Income Tax (“Imposto sobre o Rendimento do Trabalho” or “IRT”) up to Kz 100,000.00 (one hundred thousand kwanzas).
- Equity variations and latent capital gains or losses resulting from the updating of fixed assets – tangible fixed assets, intangible fixed assets and investments in real estate – at fair value must be fiscally neutral, with an impact in the 2023 fiscal year, and shall not be taken into for the purposes of assessing the taxable base for Corporation Tax (“Imposto Industrial” or “II”) purposes.
- Depreciation and amortization of fixed assets in the part resulting from the revaluation should not be tax deductible.
- The application of the rules referred to above shall depend on compliance with accounting standards, including the segregation of revaluation operations in the accounting.
- Revaluation amounts recognized in equity are not distributable as dividends.
- The possibility of submitting the II return in paper should be eliminated.
- Costs incurred by taxpayers in the agricultural and livestock sector with investments in infrastructure necessary for the production and flow of products must be considered tax deductible, for a period of five years, subject to prior approval by the Angolan general tax authority (“Administração Geral Tributária” or “AGT”).
The concept of non-regularized tax situation is extended to taxpayers who are in breach of any obligation provided for in the tax laws.
© 2024 PwC. This communication is of an informative nature and intended for general purposes only. It does not address any particular person or entity nor does it relate to any specific situation or circumstance. PricewaterhouseCoopers Tax Services TLS, Lda. We will not accept any responsibility arising from reliance on information hereby transmitted, which is not intended to be a substitute for specific professional business advice.
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