Cabo Verde

A company or entity is deemed to be resident in Cabo Verde if its registered head office or its place of effective management is in the Cabo Verde territory.

Permanent establishment (PE)

Non-resident companies deemed to have a PE in Cabo Verde are also subject to tax in Cabo Verde. Under Cabo Verdean tax law, a non-resident company is deemed to have a PE if the non-resident company:

• has any fixed installation or permanent representation located in Cabo Verde through which, among others, activities of a commercial, industrial, or agricultural nature, or fishing and rendering of services are carried out (including agricultural, fishing, and cattle raising explorations, or other quarries or any other places of natural resources extraction) or
• carries out its activity in Cabo Verde through:
  • employees, or any other personnel hired for that purpose, for a period (continuous or not) of not less than 183 days within a 12-month period
  • a person (a dependent agent), which is not an independent agent, acting, in the Cabo Verde territory on behalf of a company, with powers to intermediate and conclude binding contracts for that company, within the scope of its business activity, or
  • a building site or a construction installation if it lasts for more than 183 days, as well as activities of coordination, supervision, and inspection related with the building site or its construction installation.

A PE is also recognised in case of:

• Commissionaire arrangements.
• Preparatory or ancillary activities carried out by closely related enterprises through a fixed installation.
• Independent agents acting exclusively, or almost exclusively, on behalf of one or more closely related enterprises.

A PE of a non-resident is taxed as a resident company.