Major taxpayers that are members of an economic group may opt to be taxed under the tax regime of group taxation.
The option for the group taxation regime is available when:
- The company is included in the major taxpayers list.
- The parent company holds, directly or indirectly, at least 90% of the share capital of other companies (controlled entities), and more than 50% of the voting rights.
Some limitations apply, and the option to apply group taxation depends on the approval of the tax authorities.
Under a special regime for 'so-called' major taxpayers, being the ones identified in a list published by the Ministry of Finance, there are additional specific reporting and administrative obligations, namely the obligation of audited accounts and to prepare special transfer pricing documentation (e.g. the same will have to, under certain requisites, organise their transfer pricing documentation and submit it to the tax authorities). This is applicable to those major taxpayers that have registered annual profits higher than AOA 7 billion.
Interest arising from shareholder loans should be deductible for tax purposes up to the limit that would result from the annual average interest rate established by the Angolan Central Bank.
Controlled foreign companies (CFCs)
There are no CFC rules in Angola.