Mozambique

Changes to CIT Code

Law No. 12/2025, of 29 December, published in the Official Gazette No. 248, introduced a set of amendments to the Corporate Income Tax (CIT) Code, approved by Law No. 34/2007, of 31 December, as amended.

The following articles were amended: 3, 5, 20, 62, 67 and 75. Articles 39, 47, 75 (2) and 76 of the Code were revoked, and Article 61-A was added.

Main highlights:

• Permanent Establishment: 
  • Shorter permanent establishment period:reduced to 90 days for construction, installation and assembly projects.
  • Services permanent establishment: Introduction of a rule creating a permanent establishment where services, including consultancy and professional services, are provided for more than 90 days, in aggregate within any 12‑month period, regardless of physical presence.
• Digital Economy Taxation: 
  • For legal purposes, the concept and definition of digital goods and services have been introduced.
  • New rules for the taxation of digital goods and services, including those rendered by non-residents, which are now subject to 10% withholding tax.
• Electronic Currency Commissions: Commissions on electronic currency transactions are now subject to 10% withholding tax.
• Capital Gains:
  • Capital gains are now subject to autonomous taxation at 32%.
  • The reinvestment regime applicable to capital gains arising from the sale of fixed assets has been revoked.
• Taxable event on withholding tax: Inclusion of the moment of cost recognition as one of the triggering events for withholding tax purposes.
• Mandatory computerized accounting: Companies must maintain accounting records in   computerized financial reporting systems.
• Elimination of special regimes: The simplified bookkeeping and income determination regimes have been eliminated. Taxpayers previously registered under these regimes are required to transition to, and be classified under, the organised accounting regime.

Monthly VAT invoice reporting requirements (effective May 2025)

Through a Notice issued in March 2025 by the General Directorate of Taxation, the MTA announced new VAT reporting obligations effective May 2025, in line with Article 27(10) of the VAT Code. Taxpayers issuing sales invoices electronically must extract and submit invoice data from MTA-certified invoicing software for the previous month by uploading a compressed file to the ’e-declaração‘ Portal.

The invoice file must include key transaction details, such as dates, customer identification, descriptions of goods or services, unit and total amounts, and applicable VAT. Taxpayers with high volumes of transactions may submit data in smaller batches (e.g. daily or weekly), while others may file a single monthly report.

This measure forms part of broader efforts to modernise tax administration and aligns with Mozambique’s ongoing preparations for the future adoption of the Organisation for Economic Co-operation and Development’s (OECD’s) Standard Audit File for Tax (SAF-T). Software developers and taxpayers are urged to ensure their systems comply with both the current invoice reporting requirements and the forthcoming SAF-T framework.

Notwithstanding the above, it is worth noting that the regulatory framework for the implementation of the SAF-T is currently under public consultation, pending government approval and publishing, with full enforcement expected in near future.